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Incident Tracker / United States (state)

LPC Commercial Services, LLC v. Ar-Razzaaq Properties, LLC, Record No. 1407-25-4 (Va. Ct. App.)

·Court of Appeals of Virginia·US-STATESanctions

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 noted that no monetary losses were claimed or established.

Analysis
Virginia appeal brief drew CLE sanction after 25 phantom quotes
Court
Court of Appeals of Virginia
Date
2026-08-25
Who used the AI
Lawyer
AI tool
Not identified in the record
Conduct
Appellee's brief contained 25 phantom quotations attributed to Virginia cases. The Court of Appeals concluded the source was unchecked computer-assisted research, affirmed the judgment, and required counsel to complete a continuing legal education course on AI or appellate practice within six months.
Outcome
Sanctions
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • Twenty-five of 26 purported direct quotes to Virginia case law in RAZ's brief — the court did not enumerate them and said the 25 appeared to be pure invention
  • One additional purported direct quote to Virginia case law — differed from the source material by only a word

What the court said

“RAZ’s brief contains 26 purportedly direct quotes to Virginia case law. Troublingly, none of the alleged quotes are exact matches.”
Court of Appeals of Virginia, p. 7 n.6
“One of the “quotes” differs from the source material by only a word, while the other 25 appear to be pure invention.”
Court of Appeals of Virginia, p. 7 n.6
“Thus, we are left to conclude that the source of the phantom quotes was some form of computer-assisted research that went awry.”
Court of Appeals of Virginia, p. 19
“we call upon counsel to complete a continuing legal education course relating to AI or appellate practice within six months of the issuance of this opinion.”
Court of Appeals of Virginia, p. 20

Timeline

  1. Court of Appeals issued published opinion, affirmed judgment, and ordered AI or appellate-practice CLE.

Why this case matters

LPC Commercial Services widens the tracker from fake cases to fake words inside real law. The court counted 26 supposed direct quotations and found none exact, with 25 appearing invented. That makes it close to State v Coleman, but the Virginia remedy was narrower: no fine, no referral, and no struck brief, only required CLE and a published warning. The opinion also addresses opponent-side duties by noting proposed Virginia ethics guidance for briefs with AI-hallucinated misstatements.

Practice note

Quote-checking must compare the quoted words against the cited Virginia opinion, not merely confirm that the case exists. Counsel should keep a citation table with the exact source text, pinpoint and proposed brief quotation. Before filing, another reviewer should sample or verify all direct quotes, especially where research software or AI helped draft the brief.

Primary sources for this incident

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “LPC Commercial Services, LLC v. Ar-Razzaaq Properties, LLC, Record No. 1407-25-4 (Va. Ct. App.)”, safelegalai.com/tracker/lpc-commercial-services-v-ar-razzaaq-properties (accessed 2026-10-07). Data: CC BY 4.0.

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