California attorney fined $10,000 for filing appeal with fake AI citations
The California appeals court fined Amir Mostafavi $10,000 after discovering 21 of 23 quotes in the opening brief were fabricated by ChatGPT. The ruling serves as a warning to lawyers about the dangers of submitting unverified AI content.
Large language models confidently state falsehoods as facts, particularly when there are no supporting facts.
Key facts
- What
- The California appeals court fined Amir Mostafavi $10,000 after discovering 21 of 23 quotes in the opening brief were fabricated by ChatGPT.
- Incident date
- Jul 1, 2023
- Who
- Amir Mostafavi
- Failure mode
- Hallucination
- AI surface
- Chatbot
- Severity
- Medium
What happened
Attorney Amir Mostafavi used ChatGPT to draft an appeal brief submitted in July 2023. The California 2nd District Court of Appeal found that 21 of 23 quotes cited in the brief were fabricated. He was fined $10,000 for filing a frivolous appeal and wasting judicial resources.
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 fake legal cases and quotes to satisfy the user9s request to improve the text. The failure was compounded by the attorneys failure to personally verify the legal authority before submission.
What it cost
Sources
- PressCalifornia issues historic fine over lawyer99s ChatGPT fabricationscalmatters.org
- PressCalifornia attorney fined $10K for filing appeal with fake legal citations generated by AIthedailyrecord.com
Cite this entry
https://failureindex.ai/failures/california-attorney-fined-000-filing-appealAI Failure Index. "California attorney fined $10,000 for filing appeal with fake AI citations" (FI-0209). Realm Labs. https://failureindex.ai/failures/california-attorney-fined-000-filing-appeal (indexed Jun 5, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0209. 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.