Lnu v. Blanche
9th Cir. CA · Jun 3, 2026
- Jurisdiction
- federal
- Court
- 9th Cir. CA
- Record ID
- lnu-v-blanche-2026-06-03
- Observed outcome
- The court imposed a $2,500 monetary sanction on each attorney, a six-month suspension from practice before the 9th Circuit, and a requirement to notify other courts of the disciplinary action.
- Known monetary consequence
- $5,000
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Immigration
- Appellate
- Monetary
- AI attribution
- Alleged
- Recorded tool
- Unidentified
- Known monetary consequence
- $5,000
- Procedural posture
- 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.
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
The court noted the attorneys denied using AI, but the order addresses AI-related hallucinations.
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
- Implement a mandatory verification protocol requiring attorneys to personally read and confirm the existence and accuracy of every cited authority before filing.
- Establish a policy requiring immediate disclosure to the court and opposing counsel upon discovery of any error in a filing, including the source of the error.
- Prohibit the delegation of citation and quotation verification to AI tools or subordinates without rigorous final review by the signing attorney.
- Maintain a record of internal review and sign-off for all citations and factual assertions in court filings.