Ruiz v. Magellan Financial & Insurance Services

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

On July 8, 2026, the Court issued an order to show cause (“OSC”) requiring Plaintiff's counsel, Elizabeth Tate, to show cause why she should not be sanctioned or disciplined for including, in Plaintiff's response to Defendant's motion for attorneys’ fees, two false quotations from Ninth Circuit cases. ... Ms. Tate utilized Claude AI to help her research and prepare the Response ....After Claude prepared a draft brief incorporating the arguments Ms. Tate asked it to make, Ms. Tate entered the following query: ‘Now please make a list of the cited cases for me to review on lexis to make sure I agree with the way you've cited them.’ Claude generated a list of fourteen cases. ... But it appears that instead of reviewing the Claude-generated brief in a thorough line-by-line manner, confirming the accuracy of each citation as it arises during her review of the brief as a whole, Ms. Tate simply asks Claude to list the cases that Claude used when drafting the brief and then uses that list (rather than the brief) for purposes of her verification efforts. ... it does not strike the Court as responsible to allow an AI program to draft an entire brief and then submit that brief, without significant attorney reworking, as the attorney's own work product. Needless to say, Claude is not a licensed attorney permitted to practice law in the District of Arizona. ... Separately, during trial, Ms. Tate filed “Plaintiff's Brief on Impeachment.” (Doc. 124.) That brief contained the following purported quotation from United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001): “Rule 607 permits impeachment by contradiction, or the admission of extrinsic evidence to impeach specific errors or falsehoods in a witness's testimony.” (Id. at 2.) The quoted language, however, does not appear in Antonakeas. ... It appears to the Court that the additional examples identified above may also be attributable to the misuse of generative AI. ... IT IS ORDERED that within 14 days from the date of this order, Ms. Tate shall file a supplemental memorandum, not to exceed 10 pages, addressing the issues raised in this order.

Authorities cited in the passage: United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001) · United States v. Osazuwa, 564 F.3d 1169 (9th Cir. 2009) · Malkeet Lnu v. Blanche, 177 F.4th 1014 (9th Cir. 2026) · 28 U.S.C. § 1924 · State Bar of Arizona, Guidance For The Use of Generative Artificial Intelligence In The Practice Of Law In Arizona (Apr. 22, 2025)