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Incident Tracker / United States (federal)

Lnu v. Blanche, No. 24-4790 (9th Cir.)

·US Court of Appeals for the Ninth Circuit·US-FEDSuspension

The Ninth Circuit disciplined attorneys Mike Singh Sethi and William Rounds for filing immigration briefs with nonexistent cases, misattributed quotations and gross misrepresentations from AI hallucinations, then denying AI was the source. The panel suspended both from practice before the court for six months, fined each $2,500, and served its order on the State Bar of California.

Court
US Court of Appeals for the Ninth Circuit
Date
2026-06-03
Who used the AI
Not recorded
AI tool
Not identified in the record
Conduct
Attorneys Mike Singh Sethi and William Rounds, representing an immigration petitioner, filed briefs containing multiple nonexistent cases, misattributed quotations and gross misrepresentations of real authorities that were the product of generative-AI hallucinations. In a 'Motion to Correct' they characterized the fabrications as innocent typographical errors and affirmatively denied that generative AI might have been the source — a repeated failure of candor the panel found aggravating.
Outcome
Suspension
Penalty
US$5,000
Regulatory outcome
State Bar of California: The Ninth Circuit ordered the Clerk to serve its disciplinary order on the State Bar of California and any other applicable licensing authorities for further proceedings as appropriate. No state-bar disposition is yet on record. (2026-06-03)
Status
Verified against listed sources
Last checked
2026-09-03

What was fabricated or misused

  • Eduardo v. Garland, 28 F.4th 742 (9th Cir. 2022) — non-existent case cited in the Lnu opening brief and in Contreras Pelayo v. Bondi
  • Lay v. Holder, 729 F.3d 962 (9th Cir. 2013) — non-existent case cited in the Lnu opening brief
  • Quotation attributed to Kamalthas v. INS, 251 F.3d 1279, 1284 (9th Cir. 2001): “An adverse credibility determination is not necessarily a death knell to CAT protection.” — not in the opinion
  • Quotation attributed to Avendano-Hernandez v. Lynch, 800 F.3d 1072, 1080 (9th Cir. 2015): “The BIA must consider all evidence of record, including evidence of country conditions, in assessing the possibility of future torture.” — not in the opinion
  • Udo v. Garland, 32 F.4th 1198 (9th Cir. 2022) — offered as a replacement for Eduardo on country-conditions corroboration, but did not discuss that proposition
  • Lai v. Holder, 764 F.3d 1098 (9th Cir. 2014) — offered as a replacement for Lay on witness corroboration, but did not support the specific holding cited
  • Bandari v. INS, 227 F.3d 1160, 1167 (9th Cir. 2000) — reply-brief quotation about failure to remember non-material details did not appear in the opinion
  • Singh v. Gonzales, 491 F.3d 1090, 1096–97 (9th Cir. 2007) — cited for adverse credibility, but the case does not discuss adverse credibility
  • Zahedi v. INS, 222 F.3d 1157, 1165 (9th Cir. 2000) — represented as concerning affidavits, but the opinion does not discuss affidavits
  • Garcia v. Garland, 60 F.4th 1239 (9th Cir. 2023) — non-existent case cited in Anguiano Alvarado v. Bondi
  • Hernandez v. Sessions, 873 F.3d 1120 (9th Cir. 2017) — non-existent case cited in Anguiano Alvarado v. Bondi
  • Vasquez-Zavala v. Garland, 69 F.4th 1086 (9th Cir. 2023) — non-existent case cited in Anguiano Alvarado v. Bondi
  • Gutierrez-Alm v. Garland, 72 F.4th 446 (9th Cir. 2023) — non-existent case cited in Contreras Pelayo v. Bondi

What the court said

“Attorneys Mike Singh Sethi and William Rounds filed briefs in this Court with multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases.”
US Court of Appeals for the Ninth Circuit, slip op. at 5
“We do not sanction Sethi and Rounds for the simple fact that they or their subordinates used generative AI.”
US Court of Appeals for the Ninth Circuit, slip op. at 13
“If an attorney files a brief with cases or quotations that do not exist, or completely misrepresents what a real authority stands for, it generally does not matter if he pulled the hallucination or misrepresentation from the output of an artificial intelligence tool or from his own natural intelligence.”
US Court of Appeals for the Ninth Circuit, slip op. at 16–17
“Candor requires admissions of uncertainty just as much as it requires revealing facts known for certain.”
US Court of Appeals for the Ninth Circuit, slip op. at 27

Timeline

  1. Petition for review filed in the Ninth Circuit.
  2. Opening brief submitted for filing.
  3. Reply brief submitted for filing.
  4. Motion to Correct the Record filed.
  5. Court granted the petition, remanded, and issued an order to show cause.
  6. Published disciplinary order suspended both attorneys and served licensing authorities.

Why this case matters

Lnu v Blanche moves beyond simple fake-citation sanctions. The Ninth Circuit disciplined both the signing lawyer and the lawyer who argued the case because the later correction, argument and response treated AI hallucinations as typographical errors and denied possible AI use. Compared with Noland v Land of the Free, which centered on fabricated quotations in a state appeal, Lnu adds appellate-lawyer candor: uncertainty about AI use had to be disclosed once the errors were discovered. The six-month suspension also makes it one of the tracker’s stronger court-imposed practice restrictions.

Practice note

When a brief writer or AI tool may have produced a citation, the lawyer signing the filing must read the authority personally before filing. If a hallucination is later found, the correction should name the fake citation, disclose the likely source, withdraw the unsupported argument if needed, and notify the court and opposing counsel immediately.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Lnu v. Blanche, No. 24-4790 (9th Cir.)”, safelegalai.com/tracker/lnu-v-blanche (accessed 2026-09-16). Data: CC BY 4.0.

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