Overview

• In People v. Alvarez, the Fourth District Court of Appeal fined Attorney Siddell $1,500, ordered State Bar notification, and noted he withdrew after acknowledging a hallucinated citation and misstatements of law.
• The court, led by Justice Judith McConnell, stressed particular concern for criminal defendants’ due-process rights when filings contain nonexistent or misstated cases.
• In a separate September opinion, Noland v. Land of the Free, the Court of Appeal imposed a $10,000 sanction, found fabricated and misquoted authorities tied to AI output, and directed notice to the California State Bar.
• The Noland opinion states that no filing should include citations the responsible attorney has not personally read and verified, calling failures a breach of duties to client and court.
• Broader tracking shows at least 113 U.S. decisions since mid-2023 addressing AI-driven citation errors, with penalties reaching $31,000 and judges ordering fee payments or record corrections, even as ABA data shows law-firm AI adoption rising.