New CA Case: Don't Submit Unreviewed Fake AI-Generated Case Citations!
Oct 03, 2025New California Court of Appeal Case
Do you want to be sanctioned $10,000 and reported to the State Bar? Just file a brief with AI-generated fake case citations.
Last month, the Court of Appeal issued a stern warning to all California attorneys about submitting fake AI-generated case citations in their briefs:
Noland v. Land of the Free, L.P. (2025) __ Cal.App.5th __, 2025 WL 2629868: The Court of Appeal affirmed the trial court’s summary judgment for defendants in plaintiff’s action alleging numerous employment-related claims. The trial court properly found there were no triable issues, concluding plaintiff was an independent contractor not entitled to wage and hour protections, that she was not owed commissions, and that she failed to show adverse employment actions or emotional distress damages. Court of Appeal observed that this case was, in most respects, unremarkable and would not generally be published. However, it issued a published opinion and sanctioned plaintiff’s counsel $10,000 for submitting opening and reply briefs with numerous AI-fabricated case citations, issuing a stern warning to all California attorneys that no brief, pleading, motion, or any other paper filed in any court should contain any citations— whether provided by generative AI or any other source—that the attorney responsible for submitting the pleading has not personally read and verified. Plaintiff’s counsel was ordered to serve the opinion on his client. The clerk of the court was ordered to serve a copy of the opinion to the State Bar of California. (C.A. 2nd, September 12, 2025.)
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Monty A. McIntyre, Esq.
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