Was Del Biaggio v. Bansen sanctioned over AI-generated citations?

Del Biaggio v. Bansen (CA California, July 10, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Monetary penalty: $1,500 payable to the clerk of the court within 30 days of remittitur; opinion forwarded to the State Bar of California; client notice and certification required. $1,500 in monetary penalties.

Which AI tool was involved in Del Biaggio v. Bansen?

The order in Del Biaggio v. Bansen does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

July 10, 2026 · AI sanctions database

Del Biaggio v. Bansen

Del Biaggio v. Bansen is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: CA California
Date: July 10, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Monetary penalty: $1,500 payable to the clerk of the court within 30 days of remittitur; opinion forwarded to the State Bar of California; client notice and certification required
Penalty: $1,500 in monetary penalties.

FineBar referralProfessional sanction

What the record shows

The California Court of Appeal, First Appellate District, ordered appellant's counsel to pay $1,500 to the clerk of the court after his opening brief carried quotations the court could not locate in the cited opinions, including language attributed to a decision whose reporter citation matched a different case. Counsel's declaration stated his office uses generative AI with protocols requiring human verification and blamed a communication error with a paralegal. The court held the described protocol would not have satisfied State Bar guidance requiring the lawyer to review all AI outputs, ordered the opinion forwarded to the State Bar, and required counsel to give his client a copy and certify he had done so.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · CA California

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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