Park v. Kim, 91 F.4th 610 (2d Cir. 2024), No. 22-2057

Summary

Minhye Park appealed the Eastern District of New York's August 2022 dismissal of her suit against David Dennis Kim for repeated, willful failure to comply with court orders. The Second Circuit affirmed on January 30, 2024. It separately found that Park's counsel, Jae S. Lee, had cited a non-existent state court decision in her reply brief, which she admitted came from ChatGPT and which she had not read or verified. The court referred her to its Grievance Panel and ordered her to give her client a copy of the decision. No outcome of the grievance referral was found.

Key dates

1. January 30, 2024Filed
2. January 30, 2024Resolved
3. October 16, 2026Checked against sources
4. October 21, 2026Checked against sources

Developments are added when the record is reviewed. Next review: October 16, 2027.

Evidence

Each passage is quoted from its source. The quoted passages are re-checked against the live pages every month.

1. Park v. Kim , Case No. 22-2057 (2d Cir. Jan. 30, 2024) (Parker, Nathan, Merriam, JJ.) ( per curiam ).

   Supports: citation and panel

   Deception Inspection: Attorney Faces Discipline for Citing Fake Law The National Law Review Reporting or analysis

2. Because this conduct falls well below the basic obligations of counsel, we refer Attorney Lee to the Court's Grievance Panel, and further ORDER Attorney Lee to furnish a copy of this decision to her client.

   Supports: referral of counsel to Grievance Panel

   Plaintiff-Appellant Minhye Park appeals from an August 25, 2022, judgment of the United States District Court for the Eastern District of New York (Chen, J.)

   Supports: parties and underlying judgment

   Accordingly, we AFFIRM the judgment of dismissal.

   Supports: affirmance

   Case 22-2057, Document 178-1, 01/30/2024, 3606898, Page1 of 12

   Supports: docket number and decision date

   Opinion, Park v. Kim, No. 22-2057 (2d Cir. 30 Jan. 2024) U.S. Court of Appeals for the Second Circuit (via GovInfo) Primary source