Was Noland v. Land sanctioned over AI-generated citations?

Noland v. Land (Ct. App. Cal., 2d Dist., September 12, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Monetary sanction: $10,000 payable to the clerk; State Bar notified; opinion served on client. $10,000 in monetary penalties.

Which AI tool was involved in Noland v. Land?

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

September 12, 2025 · AI sanctions database

Noland v. Land

Noland v. Land 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: Ct. App. Cal., 2d Dist.
Date: September 12, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Monetary sanction: $10,000 payable to the clerk; State Bar notified; opinion served on client
Penalty: $10,000 in monetary penalties.

FineProfessional sanction

What the record shows

In a published opinion the court found that nearly all of the legal quotations in counsel's opening brief and many in the reply brief were fabricated, with some cited cases not existing at all, created by generative AI tools and undetected because counsel did not read the cited cases (21 of 23 quotations in the opening brief were fabrications). The court imposed a $10,000 sanction on attorney Amir Mostafavi payable to the clerk of the court, directed him to serve the opinion on his client, and directed the clerk to serve the opinion on the State Bar.

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 ↗

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 · Ct. App. Cal., 2d Dist.

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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