Appeal Sanctions: Attorney Guilty Of Using AI Hallucinations Had His AOB Stricken, Was Sanctioned $7,500 Payable To The Appeals Court, And Allowed To File A New, Corrected AOB Within 10 Days

Dismissal Of The Appeal For This Transgression Was Too Harsh.

We have previously blogged on Noland v. Land of the Free, L.P., 114 Cal.App.5^th 426, 445 and Schlichter v. Kennedy, Case No. E083744 (4^th Dist., Div. 3 Nov. 17, 2025 (also aligned with People v. Alvarez, 114 Cal.App.5^th 1115), where appellate courts sanctioned attorneys for filing appellate briefs which included AI hallucinations. 

To this list, we can now add Shayan v. Shakib, Case Nos. B337559 et al. (2d Dist., Div. 1 Dec. 1, 2025) (published), where an AOB contained AI hallucinations.  Respondent argued for dismissal of the appeal, but the appellate court believed this was too harsh of a remedy.  Instead, it ordered appellant’s counsel to pay $7,500 to the appellate clerk, ordered a corrected AOB filed without fabrications within 10 days, and ordered the matter reported to the State Bar.