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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Noland v. Land
CA California · Sep 12, 2025
CA / stateEditorial impact: highfake citationsfabricated quotesmisrepresented authorityappellate
Direct answer
What happened in this matter?
Fabricated: Case Law | Appellant cited Goldstine v. LibertyMut. Ins. Co., 2020 WL 6216738 (W.D. Wash. 2020), which the court identified as a fabricated (nonexistent) case created by AI. Outcome: Monetary Sanction; State Bar notified; opinion to be served on client.. "In total, appellant's opening brief contains 23 case quotations, 21 of which are fabrications. Appellant's reply brief contains many more fabricated quotations. And, both briefs are peppered with inaccurate citations that do not support the propositions for which they are cited.[...]We conclude by noting that "hallucination" is a particularly apt word to describe the darker consequences of AI.…
- Why the court cared
- The record concerns whether authorities presented to the decision-maker existed and could be verified. The tracked outcome is Monetary Sanction; State Bar notified; opinion to be served on client.; the linked source controls the precise reasoning.
- Why it matters now
- If 21 of 23 quotes are fabricated you lose the case and your license — mandate quote-level verification, not just cite-checking.
Why this matter is tracked
Fabricated: Case Law | Appellant cited Goldstine v. LibertyMut. Ins. Co., 2020 WL 6216738 (W.D. Wash. 2020), which the court identified as a fabricated (nonexistent) case created by AI. Outcome: Monetary Sanction; State Bar notified; opinion to be served on client.. "In total, appellant's opening brief contains 23 case quotations, 21 of which are fabrications. Appellant's reply brief contains many more fabricated quotations. And, both briefs are peppered with inaccurate citations that do not support the propositions for which they are cited.[...]We conclude by noting that "hallucination" is a particularly apt word to describe the darker consequences of AI. AI hallucinates facts and law to an attorney, who takes them as real and repeats them to a court. This court detected (and rejected) these particular hallucinations. But there are many instances-hopefully not in a judicial setting-where hallucinations are circulated, believed, and become "fact" and "law" in some minds. We all must guard against those instances."
Operational lesson
If 21 of 23 quotes are fabricated you lose the case and your license — mandate quote-level verification, not just cite-checking.
Record details
CaliforniaSingle-state evidence scope
CourtCA California
Jurisdictionstate
Circuit9th Circuit
DateSep 12, 2025
UN
AI toolUnidentified
Party typeLawyer
OutcomeMonetary Sanction; State Bar notified; opinion to be served on client.
Known amount$10,000
Professional sanctionYes
Attribution boundary
What the record establishes about AI use
not established
The current record does not establish a specific AI tool. Do not infer AI use beyond the source.
Procedural posture
Monetary Sanction; State Bar notified; opinion to be served on client.
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Appellant cited Goldstine v. LibertyMut. Ins. Co., 2020 WL 6216738 (W.D. Wash. 2020), which the court identified as a fabricated (nonexistent) case created by AI.
- False Quotes: Case Law | Appellant attributed a quotation to Schimmel v. Levin (195 Cal.App.4th 81) that does not appear in that opinion; court found the quoted language fabricated.
- False Quotes: Case Law | Appellant quoted language attributed to Regency Health Services, Inc. v. Superior Court (64 Cal.App.4th 1496) that does not appear in the opinion; the court concluded the quotation was fabricated.
- Misrepresented: Case Law | Appellant cited Peake v. Underwood (227 Cal.App.4th 428) as supporting sanctions for filing a second dispositive motion, but the court does not address that issue; the citation was misused/false.
- False Quotes: Case Law | Appellant attributed words and a sanctions principle to Heckert v. MacDonald (208 Cal.App.3d 832) that do not appear in that opinion; the court found the quotation inaccurate.
Questions this record answers
- What happened in Noland v. Land?
- Fabricated: Case Law | Appellant cited Goldstine v. LibertyMut. Ins. Co., 2020 WL 6216738 (W.D. Wash. 2020), which the court identified as a fabricated (nonexistent) case created by AI. Outcome: Monetary Sanction; State Bar notified; opinion to be served on client.. "In total, appellant's opening brief contains 23 case quotations, 21 of which are fabrications. Appellant's reply brief contains many more fabricated quotations. And, both briefs are peppered with inaccurate citations that do not support the propositions for which they are cited.[...]We conclude by noting that "hallucination" is a particularly apt word to describe the darker consequences of AI.…
- Why does Noland v. Land matter for legal AI risk?
- If 21 of 23 quotes are fabricated you lose the case and your license — mandate quote-level verification, not just cite-checking.
- What does the public record establish about Noland v. Land?
- 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 Noland v. Land 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.