3 Jun 2026
Courts
Ninth Circuit suspends two attorneys, mandates AI-disclosure certification after fabricated citations
In Lnu v. Blanche, the Ninth Circuit suspended Orange County immigration attorneys Mike Singh Sethi and William Rounds from practicing before the court for six months and fined each $2,500, after their briefs cited two nonexistent cases — 'Eduardo v. Garland' and 'Lay v. Holder' — and misquoted several real ones. The panel said the sanction turned not on using generative AI itself but on the attorneys' lack of candor, having recast the fabrications as typographical errors rather than admitting their AI origin. For two years, filings by Sethi, Rounds, and every attorney at their firm before the Ninth Circuit must include a sworn statement disclosing any generative-AI use, naming the tool, and certifying that the signer personally verified every citation and quotation.
U.S. Court of Appeals for the Ninth Circuit