Published opinion, 22 October 2025 · source · PDF · 16 pages
VI. USE OF NONEXISTENT QUOTATIONS As this Court has observed, “[c]ourts have recently seen increasing reliance on artificial intelligence in legal proceedings, leading to the use of nonexistent citations in court documents.” Williams v. Cap.
Mr. Nawash is advised that it is not acceptable to submit filings to the Court containing nonexistent quotations. Such conduct contravenes an attorney’s duty toward his client to exercise professional judgment and responsibility.
The Court agrees with the Second Circuit that, at minimum, such rules “require that attorneys read, and thereby confirm the existence and validity of, the legal authorities on which they rely.” Park, 91 F.4th at 615. Courts have taken diverse disciplinary actions against attorneys who have filed pleadings and other court papers citing nonexistent legal authorities and quotations, ranging from striking the pleadings, see, e.g., Grant v. City of Long Beach, 96 F.4th 1255, 1256–57 (9th Cir.
16 However, if this case somehow returns to this Court, Mr. Nawash will be required to show cause why he ought not be sanctioned for his use of nonexistent quotations in his filing. VII.