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Technology,
Ethics/Professional Responsibility

Oct. 3, 2025

Four AIs, 21 fabrications, one $10,000 sanction

An attorney used AI tools to cross-check his brief. The result: 21 fabricated citations, a $10,000 sanction, and California's warning that AI exploits lawyers' cognitive biases when they're most vulnerable.

James Mixon

Managing Attorney
California Court of Appeal, Second Appellate District

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Four AIs, 21 fabrications, one $10,000 sanction
Shutterstock

$10,000. That's what it cost attorney Amir Mostafavi to learn that AI cannot verify AI. He used ChatGPT to enhance his appellate brief, then ran it through Claude, Gemini and Grok -- four platforms meant to catch each other's errors. Instead, they amplified each other's fabrications. Twenty-one fake quotations reached the Court of Appeal -- the result of an attorney abdicating his professional responsibility to verify his work. The court imposed a $10,000 sanction and publish...

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