Noland v. Land of the Free, L.P.
California Court of Appeal, Second District, Division Three · Cal. Ct. App. · California bar guidance
Verified April 26, 2026
- Citation
- Noland v. Land of the Free, L.P., No. B331918 (Cal. Ct. App., 2d Dist., Div. 3, Sept. 12, 2025)
- Decided
- September 12, 2025
Summary
Attorney Amir Mostafavi filed opening and reply briefs in a state-court employment appeal in which 21 of 23 case quotations in the opening brief were fabricated, along with additional fabrications in the reply. Mostafavi acknowledged he had used generative AI "to support citation of legal issues" and was unaware that such tools routinely hallucinate authorities. Among the invented sources were a nonexistent federal opinion (Goldstine v. Liberty Mut. Ins. Co.) and a fabricated quotation attributed to Schimmel v. Levin (2011) 195 Cal.App.4th 81, a real case that contains no discussion of the cited subject matter.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $10,000
What sanction did the court impose?
Court of Appeal affirmed summary judgment for the respondent, sanctioned Mostafavi $10,000 payable to the clerk of the court, ordered counsel to serve the opinion on his client, and referred him to the State Bar of California. The court declined to award sanctions to respondent because respondent's counsel had not flagged the fabrications.
Why does Noland v. Land of the Free, L.P. matter for law firms using AI?
Noland is California’s first published appellate opinion sanctioning an attorney for AI-fabricated citations. Its rule is unambiguous: 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. The decision is now the leading California authority cited by bar associations and trial courts addressing attorney duties of candor and competence in the use of generative AI.