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AI in the Courtroom · Fabricated citations and facts in filings

Lnu v. Blanche (Ninth Circuit suspension)

Two attorneys filed briefs containing fabricated cases and misattributed quotations, then characterized the errors as typographical and denied AI use at argument. The Ninth Circuit fined and suspended both and imposed a two-year certification requirement.

Primary document read$2,500 each; six-month suspension; two-year certification; bar referral June 3, 2026

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What happened

Attorneys Mike Singh Sethi and William Rounds filed briefs in an immigration appeal that contained fabricated cases, misattributed quotations and misrepresentations of real decisions. Research and drafting had been done by unlicensed staff, contrary to the firm's own policy.

What moved the case from error to sanction was what followed. Counsel first characterized the problems as typographical, and denied at oral argument that artificial intelligence had been involved.

What the court did

On June 3, 2026, in a published order, the panel sanctioned both attorneys. Each was ordered to pay $2,500 within 21 days. Each was suspended from practice before the Ninth Circuit for six months, beginning ten days after the order was filed. Both were required within ten days to distribute the order to their clients, to opposing counsel, to the judges in their pending cases and to the attorneys in their firm, and to certify that they had done so.

For two years, every future filing by either attorney must include a statement, under penalty of perjury, addressing whether generative artificial intelligence was used and certifying personal review of the citations. The order was served on the California State Bar and any other applicable licensing authorities.

The panel was explicit that the use of the tool was not the violation. It wrote that "Lawyers using generative AI must thus be aware of the tendency of generative AI to make these mistakes and guard against them," and located the breach at a specific moment: "the rules are not violated at the point of research and drafting, but at the point of signing and filing."

Where it stands

Lnu v. Blanche is published and therefore precedential within the circuit. The sanctions were imposed and no later modification was located as of September 17, 2026.

Among the appellate decisions collected here, Lnu v. Blanche imposes the heaviest consequence, and the reason is not the quantity of fabricated material. Compare Fletcher v. Experian, where a single lawyer drew a $2,500 sanction and no suspension on a comparable record. The distinguishing fact in Lnu v. Blanche is that counsel were asked directly and said artificial intelligence had not been used.

The obligation it engaged

The sentence about signing and filing is the most useful line any court has written on this subject for an expert, because it transfers cleanly. An expert does not violate anything by consulting a system. The obligation attaches when the report is signed, and a signed report asserts that its contents are the expert's own and that its sources exist.

The conduct engaged Clause 3 of the Standard, independent authority, and Clause 8, disclosure. The Clause 8 failure is the one that produced the suspension rather than a fine. Counsel were asked directly whether artificial intelligence had been used and said it had not. Clause 8 asks the expert to state at retention that system use will be disclosed and the record produced on request. An expert who has made that statement at the outset has no incentive to answer the question the way these lawyers answered it, because the answer costs him nothing.

The two-year certification requirement is worth noting as a forward indicator. It is, in substance, a court-imposed version of Clause 7 and Clause 8 combined: a record, and a statement about it, filed each time. An expert who already works that way would find the Lnu v. Blanche regime unremarkable. An expert who does not would find it impossible to comply with retroactively, which is the point.

Sources

What could not be confirmed

The order refers to generative artificial intelligence generally and does not name a product. Whether the State Bar of California opened a proceeding following the referral was not located.

About this entry

This entry was checked against the primary document listed in the sources. The entry for Lnu v. Blanche records conduct and what the tribunal did. It does not characterize a holding and it is not legal advice. Last checked September 17, 2026. More matters like this one are collected under the fabricated-authority matters. If something here is out of date, write to [email protected].

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