Lnu v. Blanche
9th Cir. CA · Jun 3, 2026
What happened in this matter?
The 9th Circuit sanctioned two attorneys for filing briefs with fabricated citations and false quotations. The court imposed a $2,500 fine on each attorney, a six-month suspension from practice before the court, and a requirement to notify other courts of the disciplinary order.
- Why the court cared
- The court reasoned that attorneys have a non-delegable duty to verify every citation and quotation in a filing. The court held that signing a brief constitutes an attestation of accuracy, and filing fabricated or misrepresented authorities violates procedural and ethical rules regardless of whether the source was generative AI or human error. The court further determined that the attorneys' failure to disclose the nature of the errors and their attempt to pass off hallucinations as typographical mistakes warranted more severe discipline, including suspension.
- Why it matters now
- This case establishes that the duty of candor and verification is absolute, regardless of whether errors are AI-generated or human-made. It highlights that lack of transparency regarding the source of errors can escalate disciplinary outcomes from simple fines to suspension.
Why this matter is tracked
The 9th Circuit sanctioned two attorneys, Mike Singh Sethi and William Rounds, for filing briefs containing multiple fabricated cases, misattributed quotations, and gross misrepresentations of real authorities. The attorneys initially claimed the errors were typographical and denied the use of generative AI. The court found that the attorneys violated procedural and ethical rules by signing and filing documents without verifying the existence or accuracy of cited authorities. The court emphasized that the duty of candor and competence applies regardless of whether errors originate from AI or human negligence. The panel imposed monetary sanctions, a six-month suspension from practice before the court, and mandatory notification requirements due to the attorneys' repeated failure of candor regarding the nature of the errors.
This case establishes that the duty of candor and verification is absolute, regardless of whether errors are AI-generated or human-made. It highlights that lack of transparency regarding the source of errors can escalate disciplinary outcomes from simple fines to suspension.
Record details
What the record establishes about AI use
The court noted the attorneys denied using AI, but the order addresses AI-related hallucinations.
The court issued an order to show cause why the attorneys should not be sanctioned, suspended, or disbarred, followed by a final disciplinary order after considering the attorneys' responses.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
14 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Opening brief cited a case that does not exist.
- Fabricated: Case Law | Opening brief cited a case that does not exist.
- False Quotes: Case Law | Quotation attributed to Kamalthas does not appear in that opinion.
- False Quotes: Case Law | Quotation attributed to Avendano-Hernandez does not appear in that opinion.
- Misrepresented: Case Law | Real cases were represented as supporting propositions they do not discuss (mischaracterization of holdings).
- Misrepresented: Case Law | Real case cited for a point about affidavits when the opinion does not discuss affidavits.
- Fabricated: Case Law | Additional fabricated citations identified in other briefs filed by the same attorney.
- Fabricated: Case Law | Fabricated citations identified in another matter filed by the same attorney.
Show 6 additional discrepancies
- Fabricated: Case Law | Opening brief cited a case that does not exist; Court found the citation fabricated and replacement citation (Udo) did not support the claimed proposition.
- Fabricated: Case Law | Opening brief cited a second case that does not exist; Court found no plausible typographical explanation and replacement citation (Lai) did not support the original point.
- False Quotes: Case Law | Quotation attributed to Kamalthas appears in the brief but the quoted language does not appear in Kamalthas; Court treated this as a false quotation.
- False Quotes: Case Law | Quotation attributed to Avendano-Hernandez does not appear in that opinion; Court flagged as misattributed quotation.
- Misrepresented: Case Law | Court found that Singh was cited for propositions about adverse credibility and translation errors although the opinion concerns timeliness/equitable tolling; characterized as gross misrepresentation of a real case.
- Fabricated: Case Law | Court identified multiple additional fabricated citations in other briefs filed by the same attorney (examples listed) and treated these as further fabricated authorities.
Questions this record answers
- What happened in Lnu v. Blanche?
- The 9th Circuit sanctioned two attorneys for filing briefs with fabricated citations and false quotations. The court imposed a $2,500 fine on each attorney, a six-month suspension from practice before the court, and a requirement to notify other courts of the disciplinary order.
- Why does Lnu v. Blanche matter for legal AI risk?
- This case establishes that the duty of candor and verification is absolute, regardless of whether errors are AI-generated or human-made. It highlights that lack of transparency regarding the source of errors can escalate disciplinary outcomes from simple fines to suspension.
- What does the public record establish about Lnu v. Blanche?
- 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.
- Which source supports this Lnu v. Blanche summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.