The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Published opinion, 3 June 2026 · source · PDF · 30 pages
2 LNU V. BLANCHE SUMMARY* Attorney Discipline/Use of Artificial Intelligence The panel issued an order imposing sanctions against two attorneys due to their filing of briefs containing multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases, and due to their lack of candor in revealing that these fabrications and inaccuracies were the result of hallucinations by generative AI. The panel explained that it was not imposing sanctions for the simple fact that the attorneys or their subordinates used generative AI.
That is, the rules are not violated at the point of research and drafting, but at the point of signing and filing. If an attorney files a brief with cases or quotations that do not exist, or completely misrepresents what a real authority stands for, it generally does not matter if he pulled the hallucination or misrepresentation from the output of an artificial intelligen ce tool or from his own natural intelligence. However legal papers are prepared, and however legal technology develops, the court’s procedural and ethical rules apply with equal force.
Just as faithful adherence to those rules would prevent the submission of generative AI hallucinations, such adherence would also prevent the submission of similar human- generated errors. Here, it was the attorneys’ signing and filing of briefs containing hallucinated fabrications and inaccuracies that violated procedural and ethical rules. * This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.
At every subsequent step—including a Motion to Correct, oral argument, the Response to the panel’s Order to Show Cause, and more recent filings in other cases —the attorneys knowingly or recklessly made false statements to this Court. The attorneys each violated their duty of candor when they claimed that the nonexistent cases in the opening brief were the result of typographical or copy-paste errors. In circumstances such as t hese, the duty of candor requires a transparent disclosure of the source of the errors.
Harris, Charlston Revich Harris & Hoffman LLP, Los Angeles, California, for Real Parties in Interest. ORDER Attorneys Mike Singh Sethi and William Rounds filed briefs in this Court with multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases. Sethi and Rounds claimed that the errors were the product of innocent typographical mistakes .
We have considered their response, and we now impose discipline. We have previously stricken a brief in its entirety where the brief was composed almost entirely of fabricated or inaccurate citations. Grant v.
But we have yet to explain the proper course when the brief as a whole does not merit such a consequence, or what disciplinary consequences might be warranted in such a case. We issue this disciplinary order, and explain our reasoning at some length, as a warning to the members of this Court’s bar: be aware of the risks of overreliance on generative AI, read everything cited in a court filing—whether drafted by generative AI or not—and disclose quickly and transparently generative AI hallucinations that are inadvertently included in court filings. I.
4, 2025). Sethi filed an opening brief in this case with multiple fabricated citations and quotations. 2 Sethi cited two cases that do not exist and never existed: “Eduardo v.
Docket entry 48, 3 June 2026 · source · PDF · 30 pages
Docket text. ORDER FOR PUBLICATION FILED. (Richard A. PAEZ, Carlos T. BEA, Danielle J. FORREST) Attorneys Mike Singh Sethi and William Rounds filed briefs in this Court with multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases. Sethi and Rounds claimed that the errors were the product of innocent typographical mistakes. And they repeatedly denied the possibility that generative artificial intelligence (“AI”) might have produced the errors. Having identified other cases in which Sethi or Rounds filed briefs that presented similar problems, we ordered them to show cause why they should not be sanctioned, suspended, or disbarred from practice before this Court. We have considered their response, and we now impose discipline. [SEE ORDER FOR FULL TEXT] [Entered: 06/03/2026 08:45 AM]
Case: 24-4790, 06/03/2026, DktEntry: 48.1, Page 1 of 30 2 LNU V. BLANCHE SUMMARY* Attorney Discipline/Use of Artificial Intelligence The panel issued an order imposing sanctions against two attorneys due to their filing of briefs containing multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases, and due to their lack of candor in revealing that these fabrications and inaccuracies were the result of hallucinations by generative AI. The panel explained that it was not imposing sanctions for the simple fact that the attorneys or their subordinates used generative AI.
That is, the rules are not violated at the point of research and drafting, but at the point of signing and filing. If an attorney files a brief with cases or quotations that do not exist, or completely misrepresents what a real authority stands for, it generally does not matter if he pulled the hallucination or misrepresentation from the output of an artificial intelligen ce tool or from his own natural intelligence. However legal papers are prepared, and however legal technology develops, the court’s procedural and ethical rules apply with equal force.
Just as faithful adherence to those rules would prevent the submission of generative AI hallucinations, such adherence would also prevent the submission of similar human- generated errors. Here, it was the attorneys’ signing and filing of briefs containing hallucinated fabrications and inaccuracies that violated procedural and ethical rules. * This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.
At every subsequent step—including a Motion to Correct, oral argument, the Response to the panel’s Order to Show Cause, and more recent filings in other cases —the attorneys knowingly or recklessly made false statements to this Court. The attorneys each violated their duty of candor when they claimed that the nonexistent cases in the opening brief were the result of typographical or copy-paste errors. In circumstances such as t hese, the duty of candor requires a transparent disclosure of the source of the errors.
Harris, Charlston Revich Harris & Hoffman LLP, Los Angeles, California, for Real Parties in Interest. ORDER Attorneys Mike Singh Sethi and William Rounds filed briefs in this Court with multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases. Sethi and Rounds claimed that the errors were the product of innocent typographical mistakes .
We have considered their response, and we now impose discipline. We have previously stricken a brief in its entirety where the brief was composed almost entirely of fabricated or inaccurate citations. Grant v.
But we have yet to explain the proper course when the brief as a whole does not merit such a consequence, or what disciplinary consequences might be warranted in such a case. We issue this disciplinary order, and explain our reasoning at some length, as a warning to the members of this Court’s bar: be aware of the risks of overreliance on generative AI, read everything cited in a court filing—whether drafted by generative AI or not—and disclose quickly and transparently generative AI hallucinations that are inadvertently included in court filings. I.
4, 2025). Sethi filed an opening brief in this case with multiple fabricated citations and quotations. 2 Sethi cited two cases that do not exist and never existed: “Eduardo v.
Docket entry 50, 3 June 2026 · source · PDF · 30 pages
Docket text. CORRECTED ORDER FOR PUBLICATION FILED. (Richard A. PAEZ, Carlos T. BEA, Danielle J. FORREST) Correction: counsel listing typo corrected on pg 4. [Entered: 06/08/2026 11:03 AM]
Case: 24-4790, 06/03/2026, DktEntry: 50.1, Page 1 of 30 2 LNU V. BLANCHE SUMMARY* Attorney Discipline/Use of Artificial Intelligence The panel issued an order imposing sanctions against two attorneys due to their filing of briefs containing multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases, and due to their lack of candor in revealing that these fabrications and inaccuracies were the result of hallucinations by generative AI. The panel explained that it was not imposing sanctions for the simple fact that the attorneys or their subordinates used generative AI.
That is, the rules are not violated at the point of research and drafting, but at the point of signing and filing. If an attorney files a brief with cases or quotations that do not exist, or completely misrepresents what a real authority stands for, it generally does not matter if he pulled the hallucination or misrepresentation from the output of an artificial intelligen ce tool or from his own natural intelligence. However legal papers are prepared, and however legal technology develops, the court’s procedural and ethical rules apply with equal force.
Just as faithful adherence to those rules would prevent the submission of generative AI hallucinations, such adherence would also prevent the submission of similar human- generated errors. Here, it was the attorneys’ signing and filing of briefs containing hallucinated fabrications and inaccuracies that violated procedural and ethical rules. * This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.
At every subsequent step—including a Motion to Correct, oral argument, the Response to the panel’s Order to Show Cause, and more recent filings in other cases —the attorneys knowingly or recklessly made false statements to this Court. The attorneys each violated their duty of candor when they claimed that the nonexistent cases in the opening brief were the result of typographical or copy-paste errors. In circumstances such as t hese, the duty of candor requires a transparent disclosure of the source of the errors.
Harris, Charlston Revich Harris & Hoffman LLP, Los Angeles, California, for Real Parties in Interest. ORDER Attorneys Mike Singh Sethi and William Rounds filed briefs in this Court with multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases. Sethi and Rounds claimed that the errors were the product of innocent typographical mistakes .
We have considered their response, and we now impose discipline. We have previously stricken a brief in its entirety where the brief was composed almost entirely of fabricated or inaccurate citations. Grant v.
But we have yet to explain the proper course when the brief as a whole does not merit such a consequence, or what disciplinary consequences might be warranted in such a case. We issue this disciplinary order, and explain our reasoning at some length, as a warning to the members of this Court’s bar: be aware of the risks of overreliance on generative AI, read everything cited in a court filing—whether drafted by generative AI or not—and disclose quickly and transparently generative AI hallucinations that are inadvertently included in court filings. I.
4, 2025). Sethi filed an opening brief in this case with multiple fabricated citations and quotations. 2 Sethi cited two cases that do not exist and never existed: “Eduardo v.
Docket entry 41, 4 November 2025 · source · PDF · 4 pages
Docket text. ORDER FILED. Richard A. PAEZ, Carlos T. BEA, Danielle J. FORREST
On behalf of Petitioners, Attorney Mike Singh Sethi filed an opening brief with multiple fabricated citations and quotations. Sethi cited two cases that do not exist: Eduardo v. Garland, 28 F.4th 742 (9th Cir. 2022), cited at pages 5 and 16 of Petitioners’ opening brief, and Lay v. Holder, 729 F.3d 962 (9th Cir. 2013), cited and discussed at page 16. And Sethi twice attributed quotations to opinions in which the quoted language does not appear: Kamalthas v. INS, 251 F.3d 1279, 1284 (9th Cir. 2001), at page 17 of the opening brief, and Avendano-Hernandez v. Lynch, 800 F.3d 1072, 1080 (9th Cir. 2015), at page 19. After the panel denied the parties’ joint motion to submit this case on the briefs, Sethi filed a motion to correct the record regarding errata in the opening brief... Attorneys Sethi and Rounds are each ORDERED to show cause in writing, separately, why they should not be sanctioned, suspended, or disbarred from practice before this court under Federal Rule of Appellate Procedure 46(b)(1)(B) for “conduct unbecoming a member of this court’s bar,” and under Ninth Circuit Rule 46-2(a) for “violating applicable rules of professional conduct.” See Cal. R. Pro. Conduct 3.1(a)(2) (“A lawyer shall not . . . present a claim or defense in litigation that is not warranted under existing law . . . .”); id. R. 3.3(a)(1) (“A lawyer shall not . . . knowingly make a false statement of fact or law to a tribunal . . . .”); see also Chambers v. Nasco, Inc., 501 U.S. 32, 45–50 (1991) (describing “the inherent power to impose sanctions for . . . bad faith conduct”). The response is due within 28 days of the filing of this order. 9th Cir. R. 46-2(d); 9th Cir. Gen. Ord. 12.9(a). If counsel do not file responses within 28 days, the court will take disciplinary action without further notice. See Fed. R. App. P. 46(b), (c); 9th Cir. R. 46-2(d). If counsel file responses that do not include requests for hearings, the right to a hearing will be deemed waived. Fed. R. App. P. 46(c); 9th Cir. R. 46-2(d). In addition, for the foregoing reasons, Petitioners’ Motion to Correct the Record, Dkt. 35, is DENIED. (SEE ORDER FOR FULL TEXT) [Entered: 11/04/2025 10:27 AM]
A241-692-761 A241-692-762 A241-692-763 ORDER Before: PAEZ, BEA, and FORREST, Circuit Judges. On behalf of Petitioners, Attorney Mike Singh Sethi filed an opening brief with multiple fabricated citations and quotations. Sethi cited two cases that do not exist: Eduardo v.
After the panel denied the parties’ joint motion to submit this case on the briefs, Sethi filed a motion to correct the record regarding errata in the opening brief. That motion represented the two nonexistent cases—Eduardo v. Garland and Lay v.
At oral argument, confronted with the above issues, Rounds at first insisted that artificial intelligence was not used to draft Petitioners’ briefs and that the errors were typographical.1 He later conceded that artificial intelligence might have been used by the individual who drafted the briefs, and that said individual was not yet licensed to practice law.2 Since oral argument, we have identified further issues in Petitioners’ reply brief,3 and we have identified at least two other opening briefs filed in pending cases in which Sethi cites cases that do not exist.4 1 Video Recording of Oral Argument, Lnu, et al. v.