California Appellate Court Delivers State’s First Published Ruling On AI-Hallucinated Citations In Legal Pleadings, Declares Issue of First Impression and Warns Attorneys with $10K Sanction

But it was Noland’s appeal that transformed this straightforward employment dispute into a landmark ruling on AI’s role in legal practice.

The appeals court discovered that Noland’s opening brief contained what it termed “extensive reliance on nonexistent legal authority.” Of 23 case law quotations in the brief, 21 were completely fabricated.

“Although most of the cases to which the quotes are attributed exist, the quotes do not,” the panel wrote in its published opinion. “Further, many of the cases plaintiff cites do not support the propositions for which they are cited or discuss other matters entirely, and a few of the cases do not exist at all.”

The court noted that this level of fabrication “would justify striking appellant’s opening brief or dismissing the appeal.”

Noland’s attorney, Amir Mostafavi of Mostafavi Law Group, conceded to using ChatGPT to “enhance” briefs he had written. Rather than manually proofreading the AI-generated content, Mostafavi relied on additional AI platforms including Claude, Gemini, and Grok to check for errors.