California Immigration Attorneys Reportedly Sanctioned Over Briefs Containing Probable Hallucinations in LNU v. Blanche

California immigration attorneys Mike Singh Sethi and William Rounds were reportedly sanctioned in LNU v. Blanche after Ninth Circuit filings included purportedly fabricated and materially inaccurate legal authorities. The court said unauthorized generative AI use by unlicensed brief writers was probable and found that the attorneys failed to verify the filings and repeatedly lacked candor about the errors' source.

Risk classification

• Primary risk domain: 3 Misinformation
• Primary risk subdomain: 3.1 False or misleading information

The AI system generated fabricated legal citations (hallucinations) which were presented as factual in a court brief, directly falling under the generation of false or misleading information.

Additional risk subdomains

• 5.1 Overreliance and unsafe use: The attorneys overrelied on the AI system by failing to verify the generated citations before submitting them in a critical legal proceeding.

Causal factors

• Entity: AI
• Intent: Unintentional
• Timing: Post-deployment

The incident was initiated by the AI system generating fabricated legal citations (hallucinations) during post-deployment use, which were then unintentionally submitted by the attorneys.

EU AI Act risk tier

• Risk tier: 3 Limited Risk

Limited Risk: The incident involves generative AI and chatbots producing content, which carries transparency obligations such as notifying the court when AI-generated content is used.

AI system and alleged parties

• AI system: generative AI
• AI purpose: Writing Assistant; Technical Text Generation
• Behaviour type: Assistant
• Alleged developer: Large language model developers
• Alleged deployer: Sethi Law Group, Legal professionals, Law firms
• Alleged harmed parties: United States Court of Appeals for the Ninth Circuit, Sunita Rani LNU, Malkeet LNU, Judicial integrity, Jaivin Lohan, Epistemic integrity

Harm severity

Severity ratings are based on this scale.

Highest direct severity in any category: Minor. Severity is scored from Negligible to Catastrophic in each harm category, for harm the reports describe as caused directly or indirectly by the AI system.

• Physical: direct Negligible, indirect Negligible
• Infrastructure: direct Negligible, indirect Negligible
• Property: direct Negligible, indirect Negligible
• Financial: direct Negligible, indirect Minor
• Environmental: direct Negligible, indirect Negligible
• Malicious content: direct Negligible, indirect Negligible
• Differential treatment: direct Negligible, indirect Negligible
• Civil rights: direct Negligible, indirect Negligible
• Democracy: direct Negligible, indirect Negligible
• Privacy: direct Negligible, indirect Negligible
• Psychological: direct Negligible, indirect Negligible
• Epistemic: direct Minor, indirect Minor
• Child sexual exploitation and abuse: direct Negligible, indirect Negligible

Financial

Reported: The report describes 1 incident causing total financial loss of $5,000 in court sanctions.

Directly caused: Average financial loss per occurrence: $5,000, consisting of a $2,500 sanction imposed on each of the two attorneys.

Indirectly caused: The attorneys likely suffered additional indirect financial losses due to their six-month suspension from practicing at the appeals court.

Epistemic

Reported: The report explicitly describes epistemic harm through the submission of briefs riddled with nonexistent, AI-generated cases.

Directly caused: The AI system generated fabricated legal citations that were submitted to the court, introducing false information into the legal record.

Indirectly caused: The attorneys violated their duty of candor by failing to admit the errors stemmed from AI hallucinations, attempting to pass them off as typographical mistakes.

People affected

• Occurrences reported: 1
• People reportedly harmed: 2
• People reportedly exposed: 2

Potential causes

Technology

• Generative AI Hallucinations: The AI program fabricated nonexistent legal cases and citations.

Human Factors

• Failure to Vet AI Output: Attorneys failed to check the accuracy of the AI-generated citations.
• Lack of Candor: Attorneys falsely blamed errors on typographical mistakes to cover up AI use.
• Subtle Subterfuge: An attorney corrected filings without disclosing the cases were fabricated.

Process and Methods

• Inadequate Verification Process: No process was used to cross-reference AI-generated citations with real cases.

Regulatory Environment

• Evolving Legal Standards for AI: Courts are actively defining rules and sanctions for AI-related errors.

Information quality

• Classification confidence: High
• Reason for confidence: The report from Reuters provides clear, factual details about the court's ruling, the names of the sanctioned attorneys, the specific penalties, and the nature of the AI-generated errors. There is no conflicting information regarding the core events.
• Ambiguities identified: The specific AI program used by the attorneys is not identified in the report.

Two immigration attorneys were sanctioned by the 9th U.S. Circuit Court of Appeals for submitting briefs containing AI-generated fake cases. This incident represents a minor, localized disruption to federal judicial operations that was successfully mitigated using standard legal disciplinary procedures, posing negligible overall threat to national security.

• Overall national security impact: Minor
• Scope: Single nation
• Primary target: United States
• Alleged perpetrator: Sethi and William Rounds

Threat characteristics

• Imminence: Long-term. This represents an ongoing professional conduct and technology-use issue rather than an immediate crisis requiring national security intervention.
• Autonomy: Human-controlled. The AI acted as a writing assistant tool, with humans retaining final control and responsibility over the submission of the legal briefs.
• Novelty: Established threat. AI hallucinations in legal filings are an established issue with multiple prior public cases of lawyers being sanctioned for similar actions.

Impact by dimension

• Physical security: Negligible. No physical systems, infrastructure, or human safety elements were impacted or threatened by this incident.
• Information security: Negligible. No classified information was compromised, and there is no evidence of a coordinated information warfare campaign.
• Sovereignty: Minor. The incident briefly introduced fabricated information into a federal court proceeding, mildly affecting judicial operations, but was quickly managed through standard court sanctioning procedures.
• Economic security: Negligible. The financial impact was limited to minor individual court sanctions ($5,000 total) with no threat to strategic industries or national economic stability.
• Societal stability: Negligible. While the incident may have affected the quality of legal representation for specific clients, it did not pose a large-scale threat to societal stability or civil liberties.