Zhang v. Zhang
Supreme Court of Nevada · Nev. Sup. Ct. · Nevada bar guidance
Conduct
Here an appellate opening brief cited two cases the court said its research indicated are fictional, and two real cases for propositions they do not support.
Consequence
$250 to the Supreme Court Law Library, a State Bar referral for investigation, and denial of counsel's request to file a corrected opening brief.
Lesson
Here the court paired a small monetary sanction with a State Bar referral and refused to let counsel substitute a corrected brief.
Verified September 30, 2026
- Citation
- Zhang v. Zhang, No. 90509, Order Imposing Sanctions, Referring Counsel to the State Bar for Investigation, and Denying Request to Correct Opening Brief (Nev. Apr. 22, 2026); Order to Show Cause (Nev. Mar. 23, 2026)
- Decided
- April 22, 2026
Summary
In an appeal from a district court judgment in a contract action, the Supreme Court of Nevada reviewed appellant Yanling Zhang's opening brief and, in a March 23, 2026 order to show cause, stated that "our research indicates that appellant's citations to City of Henderson v. Bldg. & Constr. Trades Council, 95 Nev. 655, 600 P.2d 939 (1979), and Blakeney v. State, 110 Nev. 1029, 1032, 879 P.2d 27, 29 (1994), are fictional." It added that citations to Certified Fire Prot., Inc. v. Precision Constr., Inc. and Coyote Springs Inv. v. Eighth Judicial Dist. Ct., while real, "do not support the legal propositions for which they are cited." The court wrote that "[i]ncluding false or misleading legal representations in legal documents crosses ethical boundaries" and that such inaccuracies "create time-consuming and challenging problems for the judiciary and lead to public mistrust of the justice system." Because "it appears that attorney Michael Lin's conduct described above may violate NRAP 28(h) and NRAP 32(a)(9)" as well as RPC 1.1, 3.1, 3.3 and 8.4, the court ordered him to show cause within 14 days why it should not impose sanctions or refer him to the State Bar.
- AI tool:
- Unidentified (neither order mentions artificial intelligence; the court stated its research "indicates" that two cited cases "are fictional" and that two real cases do not support the propositions cited)
- Sanction amount:
- $250 to the Supreme Court Law Library for violating NRAP 28(h) and NRAP 32(a)(9); referral of attorney Michael Lin to the State Bar of Nevada for investigation under SCR 104 and 105; request to file a corrected opening brief denied
What sanction did the court impose?
In its Order Imposing Sanctions, Referring Counsel to the State Bar for Investigation, and Denying Request to Correct Opening Brief, entered April 22, 2026, the panel (Stiglich, Cadish and Lee, JJ.) recounted that Lin "acknowledges the seriousness of the circumstances and requests to file a corrected opening brief." It imposed a sanction "for violating NRAP 28(h) and NRAP 32(a)(9)": Lin was to pay $250 to the Supreme Court Law Library within 14 days and provide proof of payment. Because "it appears that Mr. Lin's conduct may constitute violations of RPC 1.1 (competence), RPC 3.1 (meritorious claims and contentions), RPC 3.3 (candor toward the tribunal), and RPC 8.4 (misconduct)," it referred him to the State Bar of Nevada for investigation under SCR 104 and 105 and directed bar counsel to report within 90 days. It denied his request to file a corrected opening brief. The court's docket shows appellant's proof of payment of the sanction filed April 28, 2026, and a June 18, 2026 authored opinion on the merits (142 Nev. Adv. Opn. No. 45) with the disposition "Vacated and remanded."
Why does Zhang v. Zhang matter for law firms using AI?
Zhang v. Zhang shows the Supreme Court of Nevada raising citation problems from its own review of the opening brief. Its March 23 order to show cause stated that the court’s research “indicates” two cited cases “are fictional” and that two real cases were cited for propositions they do not support, and it tied the problem both to the appellate rules (NRAP 28(h) and 32(a)(9)) and to the rules of professional conduct. Neither order mentions artificial intelligence.
The April 22 order separated the two tracks. For the appellate-rule violations the court imposed its own sanction, $250 to the Supreme Court Law Library. For the possible professional-conduct violations it made a referral, sending counsel to the State Bar of Nevada under SCR 104 and 105 and requiring bar counsel to report back within 90 days. It also denied counsel’s request to file a corrected opening brief, without stating a reason. According to the docket, the court later disposed of the appeal on the merits as “Vacated and remanded.”
Firms documenting compliance may wish to consider that here the court denied a request to file a corrected brief, and that the same order paired the sanction with a State Bar referral; the docket shows the court later pressing the State Bar for its status report.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Verify every citation in an appellate brief against the reported decision. Here the court said its own research indicated two cited cases are fictional and two others do not support the propositions cited.
- Document the firm's process for correcting a brief once a court raises citation problems. Here the court denied counsel's request to file a corrected opening brief.
- Consider that an appellate court may refer counsel to the state bar alongside a monetary sanction. Here the court directed bar counsel to report the status of the investigation within 90 days.
Sources
Primary sources
- AI attribution is a tracker inference: neither order mentions artificial intelligence. The court stated that its research indicates two cited cases are fictional and that two real cases do not support the propositions cited.
- The sanctions order's file stamp does not reproduce legibly; its April 22, 2026 date is taken from the court's ACIS docket (docket entry filed 04/22/2026 with the same title). The orders were read from copies downloaded from ACIS by Brian; ACIS does not expose stable public document URLs, so the case docket page is cited.
- The later docket entries recording the State Bar's delayed status reports and bar counsel's August 24, 2026 report were not read beyond their docket text; the outcome of the bar investigation is not reported.