{"meta":{"exportedAt":"2026-10-23T09:22:23.933Z","formatVersion":2,"selection":{"q":"fine","system":"","harm":"","context":"","country":"","role":"","relation":"contextual","evidence":"","year":"2026","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":2,"coverage":{"cases":2,"countries":1,"languages":1,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":2,"minors":0,"coreRelations":1,"contextualRelations":2,"mixedRelations":1,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2026-arizona-appeals-court-strikes-self-represented-appellants-ai-hallucinated-citations-orders-fees-sanction","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"In his opening brief with the Court of Appeals, he made eight citations. The court found that six of them were deficient; two were cases that “simply do not exist.”","relation":"supports","source_id":"s1"}],"assertion":"The self-represented appellant's opening brief made eight citations; the court found six deficient, including two cases that do not exist.","causal_attribution":"The court's findings as reported by the Arizona Mirror."},{"id":"c2","status":"reported","evidence":[{"locator":"readily acknowledged that he relied on generative AI to write his brief; he admitted he did nothing to independently verify the citations","relation":"supports","source_id":"s1"}],"assertion":"In a written explanation and at a hearing on the false citations he acknowledged relying on generative AI to write the brief and admitted doing nothing to verify the citations.","causal_attribution":"The appellant's own acknowledgement, recorded in the opinion and reported by the Arizona Mirror."},{"id":"c3","status":"reported","evidence":[{"locator":"Accordingly, citing a hallucinated case in a legal filing is sanctionable conduct; traceable to dealing with the fake citations; appeal was also rejected because there were no supportive legal authorities for his claims once the inaccurate and false citations were stricken","relation":"supports","source_id":"s1"}],"assertion":"The court held that citing a hallucinated case is sanctionable regardless of intent, ordered him to pay the portion of the other party's attorney's fees traceable to the fake citations, and rejected the appeal because no supportive authority remained once the citations were struck.","causal_attribution":"The court's ruling as reported."},{"id":"c4","status":"reported","evidence":[{"locator":"The three-judge panel noted that court rules allow for more severe sanctions, including contempt charges and monetary fines.; isn’t a trained legal professional, it opted to narrowly sanction him","relation":"supports","source_id":"s1"}],"assertion":"The court chose this narrow sanction over contempt or fines because he said he did not intend to deceive and is not a trained legal professional.","causal_attribution":"The court's reasoning as reported."}],"effects":[{"label":"brief citations struck, appeal rejected and fee sanction ordered","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://kiowacountypress.net/content/arizona-court-appeals-citing-fake-ai-generated-cases-can-get-you-sanctioned-no-matter-your","kind":"news","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-18 (HTTP 200); no translation was needed. Republication of the Arizona Mirror (States Newsroom) report.","independence_group":"arizona-mirror-report-jul-2026"}],"version":1,"ai_roles":["own_use"],"contexts":["justice"],"unknowns":["Which generative AI tool the appellant used.","The amount of the fee award, which depended on the other party's documentation."],"geography":{"basis":"The brief was filed in, and the sanction imposed by, the Arizona Court of Appeals in a Maricopa County probate appeal. Residence is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published on the Arizona Mirror's report of the Court of Appeals opinion of 15 July 2026: a self-represented appellant acknowledged relying on generative AI to write a brief that cited nonexistent cases, and the court struck the citations, rejected the appeal and ordered him to pay the fees they caused. The parties are private persons and are not named.","reviewed_on":"2026-10-18"},"ai_involvement":{"basis":"The appellant acknowledged in a written explanation and at a hearing on the false citations that he relied on generative AI to write his opening brief, which the court found cited two nonexistent cases and misstated others; the AI-generated text reached him (communicated_with), and the court read the fabricated citations, struck them, rejected the appeal for want of authority and imposed a fee sanction for them (informed_decision_about). The tool is not named.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"Arizona appeals court strikes a self-represented appellant's AI-hallucinated citations, rejects his probate appeal and orders him to pay fees as a sanction","summary":"In a published opinion of July 2026, the Arizona Court of Appeals found that a self-represented appellant's opening brief in a probate dispute contained eight citations, six of them deficient, including two cases that do not exist. In a written explanation and at a hearing on the false citations he acknowledged relying on generative AI to write the brief and said he did nothing to verify the citations. The court struck the inaccurate and false citations, rejected the appeal because no supportive authority remained, held that citing a hallucinated case is sanctionable whether or not it is intended, and ordered him to pay the share of the other party's attorney's fees traceable to the fake citations. Because he said he did not intend to deceive and is not legally trained, the court chose this narrow sanction over contempt or fines. It described the opinion as the first published Arizona ruling on generative AI hallucinations in filings.","incidentDate":"2026-07-15","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"single_interaction","reportedDate":"2026-07-19","aiSystem":"Generative AI, not identified in the report, that the appellant said he relied on to write his opening brief, which cited two nonexistent cases and misstated others","aiProduct":"Unidentified AI drafting tool","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","financial_loss"],"harmOutcomeSummary":"According to the court, the appellant's AI-drafted brief cited nonexistent cases; the citations were struck, the appeal was rejected and he was ordered to pay the share of the other party's attorney's fees caused by the fake citations.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the self-represented appellant who used generative AI and was sanctioned.","victimAgeRange":"adult","jurisdiction":"US-AZ","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://kiowacountypress.net/content/arizona-court-appeals-citing-fake-ai-generated-cases-can-get-you-sanctioned-no-matter-your","primarySourceLabel":"Arizona Mirror (States Newsroom), republished by Kiowa County Press, July 2026: Arizona Court of Appeals on sanctions for fake AI-generated cases","firstPublishedAt":"2026-10-18T03:14:48.762612+00:00","updatedAt":"2026-10-18T03:14:48.762612+00:00","scopeVersion":"facts-v3","tags":["hallucinated-citations","self-represented-litigant","appeal","sanction","attorney-fees","arizona"]},{"id":"2026-ninth-circuit-immigration-lawyers-suspended-over-ai-hallucinated-citations-board-reciprocal-suspension","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'Sethi filed an opening brief in this case with multiple fabricated citations and quotations'; 'Sethi cited two cases that do not exist and never existed'","relation":"supports","source_id":"s1"}],"assertion":"The opening brief filed for the asylum petitioners and signed by Sethi cited two cases that do not exist and attributed quotations to real opinions that do not contain them.","causal_attribution":"The court's own finding in its order."},{"id":"c2","status":"documented","evidence":[{"locator":"'to which Rounds said that AI “was not used.”'; 'Rounds finally conceded that it was “possible” that AI might have been used by the individual who drafted the briefs'; 'Sethi Law Group employs law school graduates, who are not yet licensed attorneys, to write briefs'; 'that no licensed attorney read the cases cited by the unlicensed brief writer'","relation":"supports","source_id":"s1"}],"assertion":"At oral argument Rounds said AI was not used and later conceded it was possible that the person who drafted the briefs had used AI; the drafter was an unlicensed law graduate whose citations no licensed attorney read.","causal_attribution":"The court's record of the oral argument and of the attorneys' response."},{"id":"c3","status":"documented","evidence":[{"locator":"'that the errors were the product of unauthorized AI use by their Brief Writers and a failure to cite check'","relation":"supports","source_id":"s1"}],"assertion":"Responding to the order to show cause, the attorneys conceded that the errors were probably the product of unauthorised AI use by their brief writers and a failure to check citations.","causal_attribution":"The attorneys' concession as recorded by the court; no AI tool, prompt or output was identified."},{"id":"c4","status":"documented","evidence":[{"locator":"'Neither of them suspected the use of generative AI because the Firm prohibited its use and required the Brief Writers to check all their citations'; 'it is beyond belief that he knew for a fact that it was not used'; 'is owed to this repeated failure of candor'; 'We do not sanction Sethi and Rounds for the simple fact that they or'","relation":"supports","source_id":"s1"}],"assertion":"The attorneys said that at the time of the motion to correct they did not suspect AI because the firm prohibited its use; the court found that Rounds could not have known AI was not used, said it was not sanctioning AI use as such, and attributed the severity of discipline to their repeated failure of candour.","causal_attribution":"The attorneys' explanation and the court's findings, both from the order."},{"id":"c5","status":"documented","evidence":[{"locator":"'Sethi and Rounds are each personally sanctioned in the amount of $2,500'; 'Sethi and Rounds are hereby suspended from practice before this Court for a period of six months starting ten days after this Order is filed'; 'provide a copy of this Order to their clients'; 'serve a copy of this Order on the State Bar of California'","relation":"supports","source_id":"s1"}],"assertion":"The Ninth Circuit fined each attorney $2,500, suspended both from practice before the court for six months, ordered them to give the order to their clients in every pending case, and directed service of the order on the State Bar of California.","causal_attribution":"Established by the court's order."},{"id":"c6","status":"documented","evidence":[{"locator":"'The Board hereby suspends the respondent from practice before the Board of Immigration Appeals, the Immigration Courts, and DHS for 6 months, effective June 13, 2026.'; 'On July 1, 2026, the Board granted the Joint Petition for Immediate Suspension.'; 'previously issued unpublished on September 15, 2026'","relation":"supports","source_id":"s2"}],"assertion":"The Board of Immigration Appeals suspended Sethi from practice before the Board, the immigration courts and DHS for six months, effective 13 June 2026, after granting an immediate suspension on 1 July 2026, and designated the decision as precedent after first issuing it unpublished on 15 September 2026.","causal_attribution":"Established by the Board's decision."},{"id":"c7","status":"documented","evidence":[{"locator":"'the respondent contests the sufficiency of the evidence that he knew that certain errors in his filings were caused by the use of artificial intelligence'; 'the respondent’s claims of hardship to his clients are conclusory'; 'the application of our rules of attorney discipline to misconduct related to the use of AI is not an “outlier penalty,” as the respondent claims'","relation":"supports","source_id":"s2"}],"assertion":"Before the Board, Sethi disputed that he knew AI had been used and argued that suspension would harm his clients and was an outlier penalty for AI-related misconduct; the Board rejected these arguments.","causal_attribution":"The respondent's arguments and the Board's ruling as stated in the decision."},{"id":"c8","status":"documented","evidence":[{"locator":"'The petition for review, which we granted'","relation":"supports","source_id":"s1"}],"assertion":"The court granted the asylum petitioners' petition for review.","causal_attribution":"The court's statement; it does not address any effect of the sanctions on the clients."}],"effects":[{"label":"two attorneys were fined and suspended from practice before a federal appeals court, and one was suspended from immigration practice, over briefs with AI-hallucinated citations and false statements about them","claim_id":"c5","direction":"negative"}],"sources":[{"id":"s1","url":"https://cdn.ca9.uscourts.gov/datastore/opinions/2026/06/03/24-4790.pdf","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-14 from the court's own site (HTTP 200, PDF text extracted with pdftotext); no translation was needed.","independence_group":"ninth-circuit-order-24-4790"},{"id":"s2","url":"https://www.justice.gov/eoir/media/1463666/dl?inline","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-14 from the court's own site (HTTP 200, PDF text extracted with pdftotext); no translation was needed.","independence_group":"bia-matter-of-sethi"}],"version":1,"ai_roles":["others_use"],"contexts":["justice","work"],"unknowns":["Which AI tool the brief writers used; the order records only the attorneys' concession that AI use was probable.","Whether the State Bar of California opened proceedings after the referral.","Whether the suspensions affected the attorneys' clients; the Board found the hardship claims conclusory and no source describes a harmed client.","The date the opening brief was filed; the inspected sources do not state it."],"geography":{"basis":"The briefs were filed in and sanctioned by the US Court of Appeals for the Ninth Circuit, and the reciprocal suspension was imposed by the US Board of Immigration Appeals; the order describes the firm as based in Orange County, California. The attorneys' residence is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published as a court decision about two attorneys informed by AI-generated fabricated authorities in their briefs: the Ninth Circuit's order fines and suspends two attorneys for filing briefs with AI-hallucinated citations and for repeatedly denying the AI source, and the Board of Immigration Appeals imposes a reciprocal suspension on one of them. Both records were read in full from the courts' own sites.","reviewed_on":"2026-10-14"},"ai_involvement":{"basis":"The harm is two courts' response to AI use in filings: the Ninth Circuit order describes briefs with nonexistent cases and misattributed quotations, records the attorneys' concession that the errors were probably the product of unauthorised AI use by the firm's brief writers, and imposes fines and a six-month suspension for filing them and for repeatedly denying the AI source; the Board of Immigration Appeals imposed a reciprocal suspension on that basis. The court read the fabricated authorities in the briefs, identified them and based its discipline of the two attorneys on filing them and on their statements about their source, so the AI output informed a decision about them (informed_decision_about); no tool is named.","status":"supported"},"person_relations":["informed_decision_about"]},"name":"Ninth Circuit fines and suspends two immigration lawyers over briefs with AI-hallucinated citations and denials of AI use; immigration board follows","summary":"On 3 June 2026 the US Court of Appeals for the Ninth Circuit fined immigration attorneys Mike Singh Sethi and William Rounds $2,500 each and suspended both from practice before the court for six months. Briefs filed in an asylum petition for review cited two cases that do not exist and attributed quotations to opinions that do not contain them. In a motion to correct, the attorneys called the errors typographical, and at oral argument Rounds twice said AI was not used. In their response to the court's order to show cause, they conceded that the errors were probably the product of unauthorised AI use by the firm's unlicensed brief writers and a failure to check citations. The court said the suspension was owed to their repeated failure of candour. The Board of Immigration Appeals then suspended Sethi from practice before the Board, the immigration courts and the Department of Homeland Security for six months, effective 13 June 2026, and designated that decision as a precedent on 1 October 2026.","incidentDate":"2026-06-03","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2026-06-03","aiSystem":"Generative AI that, according to the attorneys' concession recorded by the Ninth Circuit, the firm's unlicensed brief writers probably used against firm policy; no tool is named in the order or the Board's decision","aiProduct":"Unidentified AI tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm","financial_loss","legal_harm"],"harmOutcomeSummary":"According to the Ninth Circuit's order, both attorneys were fined $2,500 and suspended from practice before the court for six months over briefs whose AI-hallucinated citations they had denied were AI errors; according to the Board of Immigration Appeals, one of them was then suspended from practice before the immigration courts, the Board and DHS for six months.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":0,"otherPeopleHarmedMin":2,"affectedCountStatus":"exact","affectedCountEvidence":"Two attorneys, each named in the Ninth Circuit order as fined and suspended; the Board's reciprocal suspension concerns one of them. The asylum applicants are not counted: the court granted their petition for review and no source reports harm to them.","victimAgeRange":"adult","jurisdiction":"US","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://cdn.ca9.uscourts.gov/datastore/opinions/2026/06/03/24-4790.pdf","primarySourceLabel":"US Court of Appeals for the Ninth Circuit, order in No. 24-4790 (3 June 2026): attorney discipline over AI-hallucinated citations","firstPublishedAt":"2026-10-14T03:02:36.457192+00:00","updatedAt":"2026-10-14T03:02:36.457192+00:00","scopeVersion":"facts-v3","tags":["united-states","legal-profession","sanction","suspension","hallucinated-citations","immigration"]}]}