Incident Tracker / United States (federal)
Ruiz v. Magellan Financial & Insurance Services, No. CV-23-02090-PHX-DWL (D. Ariz.)
·US District Court for the District of Arizona·US-FEDSanctions
After finding two fabricated Ninth Circuit quotations in a fee-opposition brief, the US District Court for the District of Arizona learned that plaintiff's counsel had used ChatGPT and uncovered further invented quotations in three more briefs. Judge Lanza found ethical violations and, per the Charlotin database coding, issued a formal public reprimand rather than a monetary fine.
- Court
- US District Court for the District of Arizona
- Date
- 2026-08-24
- Who used the AI
- Lawyer
- AI tool
- ChatGPT (admitted by counsel)
- Conduct
- Plaintiff's counsel Elizabeth Tate filed three briefs containing AI-generated false direct quotations attributed to Ninth Circuit decisions including Antonakeas, Osazuwa, Saman and Mitchell, and a fourth brief misrepresenting the law. Counsel admitted using ChatGPT after the court's second show-cause order of 28 July 2026 and argued against a State Bar of Arizona referral; the referral outcome is not confirmed.
- Outcome
- Sanctions
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
What was fabricated or misused
- Saman v. Robbins, 173 F.3d 1150 (9th Cir. 1999) — purported quotation “survived summary judgment . . . were not frivolous” does not appear in the case
- Mitchell v. Off. of Los Angeles Cnty. Superintendent of Schs., 805 F.2d 844 (9th Cir. 1986) — purported quotation that courts must be “especially careful” not to discourage civil rights claims does not appear in the case
- Ansell v. Green Acres Contracting Co., 347 F.3d 515 (3d Cir. 2003) — cited for excluding favorable-treatment evidence; Ansell affirmed admission of such evidence
- United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001) — purported quotation “Rule 607 permits impeachment by contradiction, or the admission of extrinsic evidence to impeach specific errors or falsehoods in a witness’s testimony” does not appear in the case
- United States v. Osazuwa, 564 F.3d 1169 (9th Cir. 2009) — purported quotation “[A] party can introduce otherwise inadmissible evidence when the defendant opens the door by introducing potentially misleading testimony” does not appear in the case
- 28 U.S.C. § 1924 — purported direct quotation “the bill of costs shall be verified by the affidavit of the party or his duly authorized attorney” was a fabricated paraphrase
What the court said
“Ms. Tate acknowledges that she filed three different briefs in this action that contained fake AI-generated quotations and filed a fourth brief that contained an inaccurate AI-generated case summary.”
“the Court identified “three other briefs [that] contain similar errors” and ordered Ms. Tate to address those “additional examples [that] may also be attributable to the misuse of generative AI.””
“As discussed above, this case involved conduct that was at least negligent (albeit not knowingly deceptive), was not isolated, created a potential for injury, and was accompanied by several aggravating factors.”
“IT IS ORDERED that this order constitutes a formal public reprimand. Ms. Tate must report this discipline in any context in which she is required to report past instances of attorney discipline.”
Timeline
- Fee-opposition brief filed with false quotations from Saman and Mitchell.
- Court denied the fee application and ordered Elizabeth Tate to show cause.
- Court identified Ansell, Antonakeas, Osazuwa and § 1924 problems and ordered supplemental briefing.
- Court issued a formal public reprimand and required reporting as attorney discipline.
Why this case matters
Ruiz extends the tracker's Arizona federal-court line from fake case citations to false direct quotations in otherwise real authorities. Unlike Mata v Avianca, the court found remorse and no dishonest motive, yet still treated repeated quotation errors across four filings as public discipline. The order also follows McCarthy v DEA and Malkeet Lnu v Blanche in treating a lawyer's cite-check process as insufficient when the lawyer asks an AI tool to produce a list of cases rather than checking each proposition in the filed brief. The sanction was not monetary, but it created a reportable reprimand and left any State Bar referral unresolved in the record.
Practice note
A lawyer who uses AI to draft must verify each quotation and statutory excerpt against the filed brief, not against an AI-generated case list. For every quoted phrase, open the official opinion or statute, confirm the exact words, and remove quotation marks if the language is only a paraphrase. The signing lawyer should keep the checked text with the filing record.
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, “Ruiz v. Magellan Financial & Insurance Services, No. CV-23-02090-PHX-DWL (D. Ariz.)”, safelegalai.com/tracker/ruiz-v-magellan-financial (accessed 2026-10-07). Data: CC BY 4.0.