Noland v. Land of the Free
#An attorney used ChatGPT and other AI tools to draft appellate briefs and filed them without verifying the citations. Twenty-one of twenty-three case quotations in the opening brief were fabricated. California’s Second District Court of Appeal sanctioned him in the state’s first published appellate opinion on AI-hallucinated citations.
- Impact
- A $10,000 sanction payable to the clerk of the court, plus a referral to the State Bar. It was reported as the largest fine by a California state court for AI fabrications in a court filing at the time.
A drafting agent can write anything, but a filing that cites authority should only go out if each citation resolves to a real record. Gate the filing so every cited case must exist in the authorities database. A hallucinated opinion has no record, so it cannot be filed.
{
"filings/$filingId/citations/$citationId": {
"fields": { "caseRef": "String", "quote": "String" },
"tier": "durable",
"rules": {
"read": "@user.id != null",
"create": "@user.id != null && get(/authorities/@newData.caseRef) != null",
"update": "false",
"delete": "false"
}
}
}