On 3 June 2026, the US Court of Appeals for the Ninth Circuit issued a published disciplinary order in Lnu v. Blanche, No. 24-4790, suspending attorneys Mike Singh Sethi and William Rounds from practice before the court for six months and imposing monetary sanctions. The pair had filed immigration briefs containing “multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases,” including citations to opinions such as “Eduardo v. Garland” and “Lay v. Holder” that, as the court put it, “do not exist and never existed.”
What drew the heaviest discipline was not the AI use itself but the cover-up. The panel stressed that “the rules are not violated at the point of research and drafting, but at the point of signing and filing,” and that a hallucinated citation is sanctionable “whether [pulled] from the output of an artificial intelligence tool or from his own natural intelligence.” When asked at oral argument whether generative AI produced the errors, Rounds repeatedly answered “No. AI was not used,” before eventually conceding it was “possible.” The court found the attorneys had violated their duty of candor at “every subsequent step.”
The order doubles as a warning to the court’s entire bar: “be aware of the risks of overreliance on generative AI, read everything cited in a court filing … and disclose quickly and transparently generative AI hallucinations.” The firm’s process, the court noted, left unlicensed brief writers to find supporting authority while “no licensed attorney read the cases cited.” For any organization adopting AI drafting tools, the lesson is that verification and honest disclosure, not the tool, are where professional responsibility lives.