# Noland v. Land of the Free: California's First Published Opinion on AI-Fabricated Citations ($10,000 Sanction)

> In California's first published appellate opinion on AI-fabricated citations, the Court of Appeal (2d Dist., Div. 3) found that nearly all the legal quotations in the appellant's opening brief were fabricated by generative AI tools counsel used and did not read — and imposed a $10,000 sanction on attorney Amir Mostafavi, directing the clerk to forward the opinion to the State Bar.

- Verification status: verified
- Case type: deployment
- Provider: Generative-AI legal drafting (OpenAI's ChatGPT, then other AI platforms), used unverified by appellant's counsel
- Client: California Court of Appeal, 2d Dist., Div. 3 — Noland v. Land of the Free, L.P., B331918, 114 Cal.App.5th 426 (2025), Courts / legal (AI-governance honest-negative) (named)
- Sector: legal / US / cross
- Verified on: 2026-08-01
- Canonical URL: https://theinternetninja.com/stories/noland-v-land-of-the-free-california-appeals-first-published-opinion-ai-fabricated-citations-10000-sanction-2025/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| $10,000 monetary sanction on appellant's counsel Amir Mostafavi for filing appellate briefs replete with AI-fabricated quotes and citations, payable to the clerk within 30 days of the remittitur |  |  |
| California's first published appellate opinion addressing AI-fabricated ('hallucinated') citations; clerk directed to forward the opinion to the State Bar and counsel directed to serve it on his client |  |  |

## Verification method

Signed, published state appellate opinion (Tier 1), byte-tied to Wayback (official www4.courts.ca.gov PDF, CDX sha1-b32 XTLA7QYIQA3U7HMPGYZZHS2IR6VU5POF, 2025-09-13 capture); two independent legal newsrooms (Legal Newsline / Southern California Record; Metropolitan News-Enterprise) corroborate the $10,000 sanction firsthand. All quotes verified verbatim via quotecheck.py against local captures.

## Full case file

## The problem
Sylvia Noland appealed a summary judgment against her wage-and-hour claims. What set the
appeal apart, the Court of Appeal wrote, was that "nearly all of the legal quotations in
plaintiff's opening brief, and many of the quotations in plaintiff's reply brief, are
fabricated." The quotes appellant attributed to published cases did not appear in those
cases; some cited cases did not discuss the cited topics, and a few did not exist. "These
fabricated legal authorities were created by generative artificial intelligence (AI) tools
that plaintiff's counsel used to draft his appellate briefs." Independent reporting put a
number on it: "Of 23 case quotations cited in the brief, 21 were made up, according to the
opinion" (Legal Newsline).

## What was built
This is an AI-governance honest-negative, not a deployment win. The "system" is generative
AI used as an unverified legal-drafting tool. At oral argument, counsel described the
workflow: "attorney Mostafavi explained that he wrote initial drafts of the briefs,
'enhanced' the briefs with ChatGPT, and then ran the 'enhanced' briefs through other AI
platforms to check for errors. Counsel admitted that he did not read the 'enhanced' briefs
before he filed them." The court published the opinion deliberately: "no California court
has addressed this issue. We therefore publish this opinion as a warning."

## The outcome
Affirming the judgment, the court imposed a monetary sanction on counsel for prosecuting a
frivolous appeal. Because counsel represented his conduct was unintentional and expressed
remorse, the court set a "conservative sanction of $10,000. Such sanction shall be payable
to the clerk of this court within 30 days of the filing of the remittitur." The Disposition
is explicit: "Attorney Amir Mostafavi is directed to pay $10,000 in sanctions, payable to
the clerk of this court, no later than 30 days after the remittitur is filed." The court
also directed him "to serve a copy of this opinion on his client, and direct[ed] the clerk
of the court to serve a copy of this opinion on the State Bar."

Two independent legal newsrooms reported the sanction firsthand: Legal Newsline (Southern
California Record) — "the California Second District Court of Appeal imposed a $10,000 fine
on a Los Angeles plaintiff's attorney … for submitting an opening brief riddled with
AI-generated fabrications" — and the Metropolitan News-Enterprise — Division Three "imposed
a $10,000 sanction on Mostafavi for filing opening and reply briefs in Noland v. Land of
the Free L.P."

## Path to green
The $10,000 sanction, the 30-day-after-remittitur deadline, the client-service directive
and the State Bar referral are all stated verbatim in the signed, published opinion — no
client-confirmation call is required to establish them. A green badge, if TIN carries
court-adjudicated honest-negatives, requires a human to confirm the docket's
compliance/appeal posture: whether the remittitur has issued and the $10,000 was paid, the
final State Bar Court discipline outcome (a stayed one-year suspension plus probation has
been *recommended*, per MetNews — not a final order), and whether Mostafavi petitioned the
California Supreme Court for review (none located this session).