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Noland v. Land of the Free, L.P., No. B331918 (Cal. Ct. App.)

sanctions

In the California Court of Appeal, Second District, plaintiff's counsel filed opening and reply briefs in which nearly all quotations were fabricated by generative-AI tools counsel never verified. The court imposed a $10,000 monetary sanction and directed that its opinion be served on the State Bar of California.

Date of decision/order
2025-09-12
Court
California Court of Appeal, Second Appellate District
Jurisdiction
US-STATE
AI tool
generative AI (unspecified)
Conduct
Nearly all legal quotations in plaintiff's opening brief, and many in the reply, were fabricated by generative-AI tools that counsel used and never verified. The court found the briefing riddled with citations to authority that did not say what was claimed, or did not exist.
Consequence
USD 10,000
Regulatory outcome
State Bar of California: The court directed the clerk of the court to serve a copy of its opinion on the State Bar of California, referring counsel for the fabricated AI-generated citations. (2025-09-12)

Sources

Cite this incident

SafeLegalAI Global Legal AI Incident Tracker, "Noland v. Land of the Free, L.P., No. B331918 (Cal. Ct. App.)", safelegalai.com/tracker/noland-v-land-of-the-free (accessed 2026-07-16). Data: CC BY 4.0.