Fadi El Bitar v. Julio Hernandez
W.D. Washington · Jun 2, 2026
- Jurisdiction
- federal
- Court
- W.D. Washington
- Record ID
- fadi-el-bitar-v-julio-hernandez-2026-06-02
- Observed outcome
- The court sanctioned attorney Julian Mansoor Daman $1,000 and issued a public reprimand.
- Known monetary consequence
- $1,000
Why this matter warrants attention
The court sanctioned attorney Julian Mansoor Daman $1,000 for violating Rule 11 by submitting filings containing fabricated case law generated by Google Gemini. The court held that counsel failed his nondelegable duty to verify the authenticity of the research, rejecting the delegation of this responsibility to subordinates or AI tools.
The court reasoned that Rule 11 imposes a nondelegable duty on signing attorneys to ensure filings are well-grounded in fact and law. It found that counsel's reliance on interns' AI-generated research without independent verification constituted a violation. The $1,000 sanction was deemed proportionate to deter future misconduct, considering the attorney's prompt admission, lack of prior violations, and the fact that the errors did not impact the underlying habeas proceedings.
This case reinforces that attorneys remain personally liable for AI-generated hallucinations in court filings. It clarifies that delegating research to subordinates or AI does not absolve a signing attorney of their nondelegable duty to verify the accuracy of legal citations.
Failure modes and consequences
- Fabricated Quotes
- Immigration
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Google Gemini
- Known monetary consequence
- $1,000
- Procedural posture
- Order on Sanctions following an Order to Show Cause issued on April 30, 2026.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Counsel admitted in a declaration that interns used Google Gemini.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.