# In re Nwaubani: the Fourth Circuit publicly admonishes a lawyer over nonexistent citations 'potentially derived from generative AI'

> The U.S. Court of Appeals for the Fourth Circuit's Standing Panel on Attorney Discipline publicly admonished Washington, D.C., attorney Eric Chibueze Nwaubani for filing appellate briefs that cited three nonexistent judicial opinions in Bolden v. Baltimore Gas and Electric Co. The panel opened the case 'Concerned that Nwaubani's briefing contained citations to nonexistent judicial opinions potentially derived from generative artificial intelligence (AI),' but the attorney denied using AI and the court expressly declined to decide the question: 'we don't even need to determine whether Nwaubani did or did not use that technology.' It found the conduct violated D.C. Rule of Professional Conduct 8.4(d) and Local Rule 46(g)(1)(c) and imposed a non-monetary sanction — a public admonishment; there is no dollar fine, and the opinion names no AI product as Nwaubani's.

- Verification status: pending
- Case type: deployment
- Provider: No AI product named or adjudicated — the panel opened the case over citations 'potentially derived from generative artificial intelligence,' but the attorney denied using AI and the court declined to decide whether he did
- Client: U.S. Court of Appeals for the Fourth Circuit, Standing Panel on Attorney Discipline — In re: Eric Chibueze Nwaubani, No. 25-9517 (UNPUBLISHED, per curiam), before Quattlebaum, Rushing, and Benjamin, Circuit Judges; underlying appeal Bolden v. Baltimore Gas and Electric Co., No. 23-2195. Sanctioned attorney: Eric Chibueze Nwaubani (Law Group International, Chartered, Washington, D.C.), Courts / legal (AI-governance honest-negative) (named)
- Sector: legal-services / US / cross
- Canonical URL: https://theinternetninja.com/stories/in-re-nwaubani-4th-cir-standing-panel-attorney-discipline-ai-fabricated-citations-public-admonishment-2026/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| Monetary sanction: none — no dollar fine; the sanction is a public admonishment |  |  |
| Sanction imposed: public admonishment for violating D.C. Rule of Professional Conduct 8.4(d) and 4th Cir. Local Rule 46(g)(1)(c) |  |  |
| Scale of fabrication: three nonexistent cases (one in the opening brief; two more in the reply brief), each named in the opinion |  |  |
| AI tool identified: none named as Nwaubani's — proceeding opened over citations 'potentially derived from generative artificial intelligence'; the attorney denied AI use and the court declined to decide |  |  |

## Verification method

Independent-origin appellate disciplinary document. Primary is the unpublished Fourth Circuit opinion (No. 25-9517, 10pp), retrieved from the official Fourth Circuit opinions host (www.ca4.uscourts.gov) and byte-tied to the single organic Wayback capture (sha1-b32 IUVEGC6IUARZKPFCQFUKPAXOBHJIYVER = CDX digest, capture 20260710210014). The public admonishment and the AI-suspicion framing are corroborated by two mutually independent archive-bound newsrooms — Reason/The Volokh Conspiracy (which reproduces the opinion) and Virginia Lawyers Weekly (independent narration) — two_independent on the critical claim. The three-named-cases detail is Tier-1 primary + Volokh (one_independent), carried as a supporting claim.

## Full case file

## What happened

While representing the plaintiff in *Bolden v. Baltimore Gas and Electric Co.*, "an employment discrimination appeal argued before this court," Washington, D.C., attorney Eric Chibueze Nwaubani filed appellate briefs that cited cases which turned out not to be real [source](https://www.ca4.uscourts.gov/opinions/259517.U.pdf). The Bolden panel found that one cited authority, *Nationwide Mutual Insurance Co. v. Jackson*, "did not exist" and directed him to file a revised brief and show cause [source](https://www.ca4.uscourts.gov/opinions/259517.U.pdf). The Fourth Circuit's Standing Panel on Attorney Discipline then opened a disciplinary proceeding, "Concerned that Nwaubani's briefing contained citations to nonexistent judicial opinions potentially derived from generative artificial intelligence (AI)" [source](https://www.ca4.uscourts.gov/opinions/259517.U.pdf).

The panel identified three fabricated authorities: its own opinion states it "contains citations to three nonexistent cases: Nationwide Mutual Insurance Co. v. Jackson, 548 U.S. 629 (2006), Commodity Futures Trading Commission v. Glencore Ltd., 611 F.3d 1330 (Fed. Cir. 2010) and In re Acres Properties, Inc., 100 F.3d 1307 (7th Cir. 1996)" — one cited in the opening brief and "two more nonexistent cases" in the reply brief [source](https://www.ca4.uscourts.gov/opinions/259517.U.pdf).

## The AI question the court declined to decide

This is not a technology deployment but an AI-governance outcome — and a deliberately careful one on the AI question. Asked at oral argument about his sources for the three nonexistent cases, "Nwaubani responded that he used LexisNexis, Westlaw and Google," and in his responses to the show-cause notices he maintained that he "did not use generative AI" [source](https://www.ca4.uscourts.gov/opinions/259517.U.pdf). The court did not resolve that dispute. As it explained, "we don't even need to determine whether Nwaubani did or did not use that technology," because Rule 8.4(d)'s prohibition "applies to submitting a brief with nonexistent cases no matter how it is done" [source](https://www.ca4.uscourts.gov/opinions/259517.U.pdf). Generative AI is therefore the suspicion that opened the case, not an adjudicated finding, and the opinion names no AI product as Nwaubani's.

## The sanction

Finding "by clear and convincing evidence" that the conduct "seriously interferes with the administration of justice," the Standing Panel held that Nwaubani violated D.C. Rule of Professional Conduct 8.4(d) and, in turn, Local Rule 46(g)(1)(c), and — in an unpublished per curiam opinion decided March 11, 2026 (before Judges Quattlebaum, Rushing, and Benjamin) — announced, "we issue a public admonishment" [source](https://www.ca4.uscourts.gov/opinions/259517.U.pdf). The sanction is non-monetary: there is no dollar fine. The opinion closes by ordering that Nwaubani is "PUBLICLY ADMONISHED," with the reminder that "there is no shortcut around the rules" and that "citing nonexistent decisions is not permitted" [source](https://www.ca4.uscourts.gov/opinions/259517.U.pdf).

Two mutually independent newsrooms corroborate the outcome. Reason / The Volokh Conspiracy, which reproduces the opinion, is headlined "Fourth Circuit Publicly Admonishes Lawyer for" citations to nonexistent judicial opinions [source](https://reason.com/volokh/2026/03/12/fourth-circuit-publicly-admonishes-lawyer-for-citations-to-nonexistent-judicial-opinions/). Virginia Lawyers Weekly reports that the "Fourth Circuit issues public admonishment to attorney Eric Nwaubani" over "citations to nonexistent judicial opinions potentially derived from generative artificial intelligence" [source](https://valawyersweekly.com/2026/04/21/fourth-circuit-lawyer-ai-hallucinations-filings/).

## A note on the weakest link

The critical facts here rest on the strongest possible source — the Fourth Circuit's own signed disciplinary opinion (Tier 1), byte-tied to its Wayback capture — so the two newsrooms only corroborate; they are not load-bearing. The real honesty caveat is on the AI attribution: **no source, including the primary opinion, names an AI product as Nwaubani's, the attorney denied using generative AI, and the court expressly declined to decide whether he did.** This page therefore claims only that the case was *opened* on an AI suspicion, not that AI was *adjudicated* to be the cause — and its weakest secondary, Virginia Lawyers Weekly (a regional legal trade paper), is used only to echo that same "potentially derived from" framing, never to upgrade the suspicion into a finding.

## How this was verified

- **Method:** Tier-1 court-origin appellate disciplinary opinion, retrieved this session from the official Fourth Circuit opinions host and byte-tied to its sole organic Wayback capture (`20260710210014`; sha1-b32 `IUVEGC6IUARZKPFCQFUKPAXOBHJIYVER`). Every quoted line was re-matched against the pdf-parse extraction of that capture.
- **Corroboration:** the critical claim (non-monetary public admonishment for citing three nonexistent opinions; AI suspected but expressly not decided) is carried by two mutually independent, archive-bound newsrooms — Reason / The Volokh Conspiracy (Wayback `20260312211955`) and Virginia Lawyers Weekly (Wayback `20260422105628`).
- **Date verified:** checker round 1, 2026-07-26 (confidence 1.000, two_independent on the critical claim; graduated to `pending`).
- **What "verified" (green) would still require:** a human confirming on the Fourth Circuit record that the March 11, 2026 opinion (No. 25-9517) has not been disturbed on rehearing and that the public admonishment stands. Green never depends on the sanctioned attorney confirming anything. This page is `pending` (amber); no green badge is claimed.

## Related case files

- [McCarthy v. DEA](/stories/mccarthy-v-dea-3d-cir-24-2704-ai-fabricated-citations-public-reprimand-first-impression-2026/) — the Third Circuit's precedential, first-impression **public reprimand** of an attorney for AI-fabricated citations, likewise with no dollar fine; the appellate-court analog to this non-monetary admonishment.
- [United States v. Hayes](/stories/us-v-hayes-federal-defender-1500-sanction-fictitious-citation-court-declines-to-find-ai-use-2025/) — the same "court declines to find AI use" family: a federal defender sanctioned over a fictitious citation while the court expressly declined to hold that AI was the cause.
- [Romero v. Corona Investments](/stories/romero-v-corona-investments-7th-cir-bach-ai-hallucinated-citations-admonished-no-sanction-511a-2026/) — a Seventh Circuit attorney **admonished** for AI-hallucinated citations with no monetary sanction, a close sibling on the non-monetary end of the sanctions spectrum.

## Sources

1. U.S. Court of Appeals for the Fourth Circuit, Standing Panel on Attorney Discipline · *In re: Eric Chibueze Nwaubani*, No. 25-9517 (unpublished per curiam, decided March 11, 2026) · 2026-03-11 · https://www.ca4.uscourts.gov/opinions/259517.U.pdf — **Tier 1** (primary, signed appellate disciplinary opinion; independent-origin, not counted toward corroboration; byte-tied to Wayback capture 20260710210014, sha1-b32 IUVEGC6IUARZKPFCQFUKPAXOBHJIYVER).
2. Reason / The Volokh Conspiracy · "Fourth Circuit Publicly Admonishes Lawyer for Citations to Nonexistent Judicial Opinions" · 2026-03-12 · https://reason.com/volokh/2026/03/12/fourth-circuit-publicly-admonishes-lawyer-for-citations-to-nonexistent-judicial-opinions/ — **Tier 2** (independent newsroom, reproduces the opinion; byte-tied Wayback capture 20260312211955).
3. Virginia Lawyers Weekly · "Fourth Circuit lawyer, AI hallucinations in filings" · 2026-04-21 · https://valawyersweekly.com/2026/04/21/fourth-circuit-lawyer-ai-hallucinations-filings/ — **Tier 2** (independent legal trade newsroom; byte-tied Wayback capture 20260422105628).