Superior Court Judge Will Determine The Fees To Be Awarded.
Pro per appellants are not immune from appellate sanctions for having used AI hallucinations citations in their AOB. The penalty in Varma v. The Bank of New York Mellon, Case No. E085566 (4th Dist., Div. 2 Aug. 27, 2026) (unpublished) for in pro per appellants in this position was to pay the reasonable appellate fees of respondent. Appellants admitted to the AI gaffes and apologized to the appellate court at an OSC hearing, but they made contradictory statements which tarnished their credibility. The appellate court charged the superior court with determining the reasonable fee to be awarded as sanctions, keeping in mind applicable lodestar principles.