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Virginia appeal brief drew CLE sanction after 25 phantom quotes
The Virginia Court of Appeals ordered counsel to take AI or appellate-practice CLE after an appellee brief attributed 25 phantom quotations to Virginia cases.
Edited and verified by Cognesio LLP
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In Virginia, the Court of Appeals ordered counsel to complete continuing legal education after an appellee brief attributed 25 quotations to Virginia cases that did not contain them.
The 25 August 2026 opinion in LPC Commercial Services, LLC v. Ar-Razzaaq Properties, LLC, Record No. 1407-25-4, affirmed the underlying judgment but paused to address the briefing problem. The court described the quotations as “phantom quotes” and said their volume pointed to unchecked computer-assisted research.
In Virginia, appellee’s counsel in LPC Commercial Services filed a brief with 25 phantom quotations attributed to Virginia cases, which the Court of Appeals attributed to unchecked computer-assisted research. The court affirmed the judgment, ordered counsel to complete AI or appellate-practice CLE within six months, and treated the published opinion as part of the consequence for the briefing failure.
What the court did
The Court of Appeals did not impose a monetary sanction. Instead, it ordered counsel to complete a continuing legal education course relating to artificial intelligence or appellate practice within six months. The opinion also made counsel the subject of a published warning about verification duties.
The opinion did not identify a particular AI product. That matters: the court’s finding was about the failure to verify quoted legal authority, not about a named platform. The practical defect was the same as in hallucinated-citation cases — text presented as law did not match the actual cases.
Why it matters
The sanction is narrow but operational. A CLE order tells the bar what competence now requires: lawyers using AI-assisted or computer-assisted research must check quoted language, not only case names and citations. A real case can still be misused if the words attributed to it are invented.
For law firms, the case is a reminder that cite-checking workflows need to compare quoted language against the source document, not stop after confirming that a case exists in a database.
Record: LPC Commercial Services v. Ar-Razzaaq Properties.