Noland v. Land of the Free, L.P.

What happened

Sylvia Noland appealed a summary judgment entered by the Los Angeles Superior Court in favor of Land of the Free, L.P. and Jose Luis Nazar on employment-related claims. Her lawyer, Amir Mostafavi, filed the opening and reply briefs.

The Court of Appeal found that nearly all of the legal quotations in the opening brief, and many in the reply brief, were fabricated. According to the published opinion, 21 of the 23 case quotations in the opening brief did not appear in the cited decisions. Some citations were to cases that do not exist; others attributed words to real cases that the cases do not contain. The opinion identifies the tools counsel used as ChatGPT, Claude, Gemini and Grok.

Counsel acknowledged that he did not "manually verify [the quotations] against more reliable sources." At oral argument he explained that he wrote initial drafts and then ran them through AI platforms to "enhance" them. The court recorded that he "did not read the 'enhanced' briefs before he filed them."

The respondents did not flag the fabrications. Before oral argument the court issued an order to show cause on its own motion.

What the court did

In an opinion filed September 12, 2025, the court affirmed the judgment on the merits. It then sanctioned counsel. The disposition reads: "The judgment is affirmed. Attorney Amir Mostafavi is directed to pay $10,000 in sanctions, payable to the clerk of this court, no later than 30 days after the remittitur is filed."

The court directed the clerk to serve a copy of the opinion on the State Bar and directed counsel to serve the opinion on his client. It declined to award the respondents their fees. The opinion explains that the respondents had not alerted the court to the fabricated citations and had not shown what fees they incurred.

The Metropolitan News-Enterprise reported that counsel described the citation problems as "regrettable" but unintentional.

Where it stands

The sanction and the affirmance are final for this record. The opinion was certified for publication, so it is citable authority in California courts. The outcome of the State Bar referral had not been reported as of September 11, 2026.

The obligation it engaged

The conduct engaged Clause 3 of the Expert Record Standard (independent authority). The defect was mostly in quotations rather than case names, though at least one cited case appears not to exist. A fabricated quotation attributed to a real case is harder to catch than a fictitious case, because the citation resolves. The only check that works is to open the case and find the words.

Clause 4 (checkability before adoption) is also engaged. Passing a draft through additional systems is not verification. A system that rewrites a brief can introduce authority that the author never read, and a filing that its signer has not read cannot have been checked. The governing test asks whether a competent appellate lawyer, working from the reported decisions alone, would have produced the same quotations. Here, for 21 of 23, the answer is no.

Sources

• Court of Appeal of California (via Justia) · September 12, 2025
  Noland v. Land of the Free, L.P., B331918
• Metropolitan News-Enterprise · September 15, 2025
  $10,000 Sanction Imposed Based on Fake Quotes in Briefs

What could not be confirmed

The Metropolitan News-Enterprise gives a decision date that differs from the filing date shown on the opinion (September 12, 2025); the opinion date is used. The State Bar's handling of the referral was not found.