Attorney AI use
Noland v. Land of the Free, L.P.
Twenty-one of 23 quotations in an opening brief were fabricated, with more errors in reply and an admission that counsel had not read the cases.
$10,000 sanction01
Case background
Material facts
Counsel filed opening and reply briefs prepared in part with ChatGPT, Claude, Gemini, and Grok without reading the cited decisions. The opening brief contained 23 case quotations, 21 of them fabricated. Many cited cases were real but did not contain the quoted language or support the stated propositions; a few cited authorities did not exist at all. The court explained: “Although most of the cases to which the quotes are attributed exist, the quotes do not. Further, many of the cases plaintiff cites do not support the propositions for which they are cited or discuss other matters entirely, and a few of the cases do not exist at all.” (Slip op. at 9.)
02
The decision
The court’s ruling
The court affirmed on the merits, ordered counsel to pay $10,000 to the court, required notice to the client, and sent the opinion to the State Bar.
Why it matters
What the decision means
This was the first California opinion to address AI-generated legal hallucinations, and the court published it as a warning: “Simply stated, 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.”
Primary reading