On Friday, February 27, 2026, MetNews reported that Pacific Palisades attorney Amir Mostafavi faces disciplinary action recommended by a State Bar Court judge for submitting briefs containing fabricated citations in the Third District Court of Appeal. The citations were generated using artificial intelligence tools.
State Bar Court Judge Yvette D. Roland recommended a one-year suspension, stayed, and one year of probation. The conditions include completing 10 hours of continuing legal education focused on technology, with at least half dedicated to the risks of using AI in legal work. Mostafavi has stipulated to the facts, with the California Supreme Court holding the final decision on the discipline.
The case originated on September 14, 2025, when the Third District Court of Appeal sanctioned Mostafavi $10,000 for filing opening and reply briefs in Noland v. Land of the Free L.P. that included citations and quotes from non-existent cases. Presiding Justice Lee Edmon highlighted the unprecedented nature of the situation, noting that nearly all legal quotations in the plaintiff’s opening brief and many in the reply brief were fabricated. The court found that many cited cases did not discuss the relevant topics, and some did not exist. Generative AI tools created these legal authorities, referred to as AI “hallucinations,” which went undetected by Mostafavi because he did not verify the AI-generated citations.
The court’s opinion marked the first instance in California of addressing AI use in legal document drafting. Following the sanction, Mostafavi paid the $10,000 fine and implemented changes to his citation and legal writing practices. These changes include independent verification of all case citations generated by AI and a commitment to ongoing education regarding the use of such tools.
The State Bar Court stated that Mostafavi’s use of AI tools for legal research and brief preparation without an adequate understanding of the technology’s risks led to the submission of briefs containing fabricated legal authority. The court found that Mostafavi acted recklessly and with gross negligence, failing to provide competent legal services and violating Rules of Professional Conduct, rule 1.1(a).
The disciplinary body acknowledged Mostafavi’s 12 years of discipline-free practice, evidence of good character, remorse, recognition of wrongdoing, prefiling stipulation, acknowledgment of misconduct, and changes to his legal writing practices. Judge Roland noted that the misconduct was limited to one client matter over a relatively short period and involved a relatively new technology that many lawyers did not fully understand.
Roland concluded that a stayed suspension would adequately serve the purposes of attorney discipline while informing the public and State Bar members that submitting briefs with fabricated legal authority due to AI misuse could result in significant discipline, absent significant mitigation.
Source: MetNews
