Two Orange County immigration lawyers have been sidelined by a federal appeals court after filing appellate briefs so riddled with bogus citations and mangled quotes that judges linked the mess to unchecked AI hallucinations and a serious lapse in candor.
In an order filed Wednesday, a three judge panel of the U.S. Court of Appeals for the Ninth Circuit suspended Mike Singh Sethi and William Rounds from practicing before the court for six months and personally sanctioned each of them $2,500. According to the Ninth Circuit order, the discipline stems from briefs that “contained multiple nonexistent cases, misattributed quotations, and gross misrepresentations,” compounded by the attorneys’ failure to be forthright about how the errors occurred.
What the Court Found
The opinion walks through specific misfires. The opening brief cited entirely fabricated cases, including “Eduardo v. Garland” and “Lay v. Holder,” and twice attributed language to real Ninth Circuit decisions that does not appear in those opinions at all. The panel warned lawyers to “be aware of the risks of overreliance on generative AI” and emphasized that the sanctions were driven by what was filed and by the lawyers’ lack of candor, not by the mere fact that generative AI or outside drafting help was involved. The Ninth Circuit order details the bogus citations, the misattributed quotations, and the panel’s reasoning.
Firm and the Case
Sethi and Rounds are associated with Sethi Law Group, which lists an Orange County office on the firm’s website. As reported by the San Francisco Chronicle, the disciplinary decision does not disturb the panel’s earlier November ruling in the underlying immigration appeal, which stayed the deportation of three family members from India.
New Rules for Filings and Penalties
The court’s order does more than bench the two lawyers. It directs Sethi and Rounds to promptly notify their clients and opposing counsel, to certify their compliance on a tight timetable, and to accept new disclosure obligations in every case they and their firm touch for the next two years. During that period, every filing from them or their colleagues must include a sworn statement saying whether generative AI was used, identifying any tools relied on, and certifying that the signing attorney personally checked each citation and quotation.
Coverage from Bloomberg Law notes those procedural requirements and also highlights the court’s direction that the clerk send a copy of the order to the State Bar of California, inviting possible separate disciplinary action.
Broader Signal to the Bar
The panel casts the ruling as a loud warning shot to the legal profession: it is no defense to say that faulty work product came from a staffer, a contractor, or an AI tool if the attorney who signs the brief did not verify the authorities. The judges underscored that the duty to vet legal citations and be candid with the court stays firmly with the lawyer whose name is on the line.
The Los Angeles Times and other outlets have framed the order as part of a growing series of appellate sanctions tied to AI related citation blunders and thin oversight by supervising attorneys. The L.A. Times recounted the court’s criticisms, including its reference to “AI slop,” along with the suspensions and monetary penalties imposed.
What Happens Next
The order requires Sethi and Rounds to circulate the decision to all clients, opposing counsel, and presiding judges in their active matters and then certify that they have done so. The court also instructed the clerk to alert relevant licensing authorities, leaving it to state regulators to decide whether additional discipline is warranted.
The ruling makes clear that appellate practice now comes with explicit disclosure and verification duties whenever generative AI or outside drafters are brought into the mix, a point underscored by the San Francisco Chronicle. The message from the Ninth Circuit is straightforward: the convenience of AI assisted drafting does not loosen the professional obligation to confirm that cases are real, quotations are accurate, and any mistakes are owned and corrected, and the court is fully prepared to back that principle with concrete sanctions.
