California Sanctions Lawyers for Fake AI-Generated Case Citations
Three California attorneys have been disciplined for using fabricated AI-generated citations in court filings.
Why it matters: These cases mark the first formal disciplinary actions in California for misuse of AI in court filings. The move signals to legal professionals the urgent need for robust AI governance and due diligence when using generative tools.
- Amir Mostafavi fined $10,000 after 21 of 23 citations in an appeal were AI-fabricated.
- The State Bar Court recommended Mostafavi receive a stayed one-year suspension and additional AI training.
- Sheree Wright sanctioned for at least 18 fake citations in a discrimination case against the Phoenix Suns.
- Kevin G. Little filed AI-generated bogus citations but avoided sanctions in a civil rights lawsuit.
California's legal community is witnessing its first major disciplinary response to the misuse of artificial intelligence in legal filings. Three attorneys have faced formal action after submitting documents riddled with fabricated or irrelevant AI-generated case citations, highlighting the profession's emerging ethical minefield.
- Amir Mostafavi was fined $10,000 and faces a stayed one-year suspension alongside a year of probation and mandatory training on technology and AI risks after an appeals filing where 21 of 23 citations were not real cases.
- Sheree Wright was sanctioned after submitting at least 18 fabricated citations in a discrimination suit against the Phoenix Suns, ordered to pay some opposing fees and undergo extra training on ethical AI use.
- Kevin G. Little faced scrutiny but escaped formal penalties when his use of false citations in a civil rights matter was deemed non-sanctionable by the court.
The message from California courts is direct. Presiding Justice Lee Edmon wrote: "Simply stated, no brief, pleading, motion, or any other paper filed in any court should contain any citations—whether provided by generative AI or any other source—that the attorney responsible for submitting the pleading has not personally read and verified."
Sean Harrington, Director of ASU's AI and Legal Tech Studio, reflected the profession's awareness: "I'm not surprised. This is something that's been at the forefront of attorneys' minds because it's so common."
With AI tools proliferating in law, these actions reinforce that ultimate professional responsibility remains firmly with practitioners, regardless of technological advances.
By the numbers:
- $10,000 — Fine imposed on Amir Mostafavi for fabricated AI citations.
- 21 of 23 — Number of fake citations in Mostafavi's appeal filing.
- 18+ — Fabricated references in Sheree Wright's Phoenix Suns lawsuit filings.
Yes, but: Kevin G. Little avoided sanctions, indicating disciplinary action is not automatic for AI misuse.