Was Wanyu Zhang v. National Public Radio, Inc. sanctioned over AI-generated citations?

Wanyu Zhang v. National Public Radio, Inc. (D. D.C., December 18, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Opposition stricken; counsel ordered to pay NPR reasonable fees and costs (amount to be determined). No monetary penalty in this order.

Which AI tool was involved in Wanyu Zhang v. National Public Radio, Inc.?

The order in Wanyu Zhang v. National Public Radio, Inc. does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

December 18, 2025 · AI sanctions database

Wanyu Zhang v. National Public Radio, Inc.

Wanyu Zhang v. National Public Radio, Inc. 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: D. D.C.
Date: December 18, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Opposition stricken; counsel ordered to pay NPR reasonable fees and costs (amount to be determined)
Penalty: No monetary penalty in this order.

FineProfessional sanction

What the record shows

The court found that plaintiff's opposition brief, filed by counsel Lev Ivan Gabriel Iwashko, contained two case citations the court determined were entirely fictitious and eight it found were seriously mischaracterized. Counsel explained he relied on Google search summaries he did not realize were AI-generated. The court struck the opposition and directed counsel to pay NPR's reasonable attorney's fees and costs associated with its reply, with the amount to be set in a later order. No specific AI product was identified.

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 · D. D.C.

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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