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Incident Tracker / United States (state)

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

·California Court of Appeal, Second Appellate District·US-STATESanctions

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.

Court
California Court of Appeal, Second Appellate District
Date
2025-09-12
Who used the AI
Not recorded
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.
Outcome
Sanctions
Penalty
US$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. A State Bar Court recommendation of a one-year stayed suspension, one year of probation and ten hours of technology CLE was reported in February 2026 (Metropolitan News-Enterprise, 27 Feb 2026); no final California Supreme Court discipline order located as of 3 Sep 2026. (2025-09-12)
Status
Verified against listed sources
Last checked
2026-09-03

What was fabricated or misused

  • Opening brief — 23 case quotations, 21 fabrications; reply brief contained many more fabricated quotations
  • Schimmel v. Levin (2011) 195 Cal.App.4th 81, 86–87 — quoted language about section 437c(f)(2) does not appear in Schimmel or any known case
  • Regency Health Services, Inc. v. Superior Court (1998) 64 Cal.App.4th 1496, 1504 — quoted continuance language does not appear in the opinion
  • Peake v. Underwood, 227 Cal.App.4th 428, 448 (2014) — cited for second-dispositive-motion sanctions; case does not address that topic
  • Goldstine v. Liberty Mut. Ins. Co., 2020 WL 6216738 (W.D. Wash. 2020) — appears to be a fabricated case
  • Heckert v. MacDonald, 208 Cal.App.3d 832, 837 (1989) — quoted sanctions wording does not appear in the opinion

What the court said

“What sets this appeal apart—and the reason we have elected to publish this opinion—is that nearly all of the legal quotations in plaintiff’s opening brief, and many of the quotations in plaintiff’s reply brief, are fabricated.”
California Court of Appeal, Second Appellate District, slip op. at 2
“The quoted language does not appear in Schimmel—or in any other case of which we are aware.”
California Court of Appeal, Second Appellate District, slip op. at 10
“In total, appellant’s opening brief contains 23 case quotations, 21 of which are fabrications.”
California Court of Appeal, Second Appellate District, slip op. at 10
“At oral argument, attorney Mostafavi explained that he wrote initial drafts of the briefs, “enhanced” the briefs with ChatGPT, and then ran the “enhanced” briefs through other AI platforms to check for errors. Counsel admitted that he did not read the “enhanced” briefs before he filed them.”
California Court of Appeal, Second Appellate District, slip op. at 19

Timeline

  1. Trial court denied plaintiff's sanctions motion and continued the summary-judgment hearing.
  2. Trial court heard the renewed summary-judgment motion after allowing plaintiff to file an opposition.
  3. Plaintiff filed a notice of appeal from the order granting summary judgment.
  4. Court of Appeal published sanctions opinion addressing AI-fabricated quotations.
  5. Court ordered counsel to pay $10,000 to the clerk after remittitur.

Why this case matters

Noland is the California appellate counterpart to Mata v Avianca and Shahid v Esaam: an otherwise ordinary appeal became a published warning because the briefs were filled with invented quotations. The opinion is specific about scale, identifying 21 fabricated quotations in the opening brief alone. It also rejects a proposed cure by revised briefs and sends the opinion to the State Bar, making personal verification of every quoted authority the rule for California appellate practice.

Practice note

Counsel should not quote a case until the opinion has been read in full enough to confirm the words, page reference and legal point. Running a ChatGPT-edited brief through other AI tools is not verification. If a draft contains AI-supplied citations, compare each one with the official reporter or court PDF before filing.

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Cite this record

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 2026-09-16). Data: CC BY 4.0.

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