Amir Mostafavi fined $10,000 for using ChatGPT to fabricate court quotes
California attorney Amir Mostafavi was sanctioned $10,000 by the 2nd District Court of Appeal for submitting a brief containing fabricated quotes. The court found that 21 of 23 quotations were hallucinated by ChatGPT.
The attorney submitted a brief where 21 of 23 citations were hallucinated by ChatGPT, resulting in a $10,000 court fine.
Key facts
- What
- California attorney Amir Mostafavi was sanctioned $10,000 by the 2nd District Court of Appeal for submitting a brief containing fabricated quotes.
- Incident date
- Sep 22, 2025
- Who
- Amir Mostafavi
- Failure mode
- Hallucination
- AI surface
- Chatbot
- Severity
- Medium
What happened
In the case of Noland v. Land of the Free, attorney Amir Mostafavi submitted an opening brief containing quotes generated by ChatGPT. The court found that 21 of 23 quotes were fabricated and sanctioned him $10,000, one of the largest California state court penalties for AI fabrications at the time. This incident underscores concerns about relying on AI-generated legal citations without verification.
What broke inside the model
- 01 · TriggerA user asks for a fact, a citation, or a figure.
- 02 · Model stepThe model writes a fluent, confident answer.
- 03 · Control gapNothing ties the claim back to a real source.
- 04 · FailureA fabricated fact ships as if it were verified.
- 05 · ConsequenceThe false claim reaches a customer, a court, or the public.
Confidence holds, and even spikes, as the claim detaches from any source.
The LLM hallucinated legal citations and quotes, presenting them as factual precedents. The failure occurred because the model generated plausible-sounding but non-existent legal text, which was then used in a formal court filing without verification.
What it cost
Sources
- PressCalMatters: ChatGPT lawyer fined for AI-regulation concernscalmatters.org
- PressFindLaw: Court sanctions attorney Amir Mostafavi $10,000caselaw.findlaw.com
- PressLana K-Hanna: AI misused by California attorney sanctionslanak-hanna.com
Cite this entry
https://failureindex.ai/failures/amir-mostafavi-fined-000-using-chatgptAI Failure Index. "Amir Mostafavi fined $10,000 for using ChatGPT to fabricate court quotes" (FI-0273). Realm Labs. https://failureindex.ai/failures/amir-mostafavi-fined-000-using-chatgpt (indexed Jun 5, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0273. Full dataset at /data.
Note from Realm Labs, the Index steward
How Realm would have caught this
- Prism
- OmniGuard
- AI Detection & Response (AIDR)
A runtime layer that watches the model's internal state can flag the moment a model commits to a claim it has no support for, and hold or reroute the response before it reaches a user. Realm reads those signals in real time rather than grading the transcript after the fact.