Two Cases That Never Existed. The Ninth Circuit Suspended Both Lawyers Six Months.

On June 3, 2026, three judges of the Ninth Circuit put quotation marks around a case name to make a point. "Eduardo v. Garland, 28 F.4th 742 (9th Cir. 2022)," the panel wrote, was a case that "do not exist and never existed." So was "Lay v. Holder, 729 F.3d 962 (9th Cir. 2013)." Both had been cited to the court in a brief signed by a member of its bar. "We add quotation marks to the names of fabricated cases," the order reads, "to distinguish them from real cases."

The lawyer who filed them was Mike Singh Sethi of the Sethi Law Group in Orange, California. The brief was an immigration appeal, Lnu v. Blanche, No. 24-4790. Only Sethi's name was on the briefs. At oral argument, William Rounds, of Bill Rounds Attorney at Law PC, also in Orange, appeared for the petitioners instead. Judges Richard Paez, Carlos Bea, and Danielle Forrest sat on the panel. They did not buy what came next.

What came next was a typo defense. Sethi called the fabricated citations "typographical errors" in a Motion to Correct. At oral argument, Rounds tried a softer word. The intended citations, he said, were "somewhat garbled," and "it looks like it was a copy and paste error or something like that." The panel went and checked. There were real cases buried under the fakes. "Eduardo v. Garland" had started life as Udo v. Garland. "Lay v. Holder" had been Lai v. Holder. The volume numbers, the page numbers, the years, none of them lined up with the real ones either.

So the court did the math out loud. "We have not identified any plausible explanation," the order states, "for how innocent typographical or copy-paste errors could turn Udo v. Garland and Lai v. Holder into 'Eduardo v. Garland' and 'Lay v. Holder,' the clearly hallucinated citations." A slipped finger turns Udo into Odo. It does not turn Udo into Eduardo. The defense did not survive contact with the page numbers.

The fake cases were not the whole of it. Sethi had also pulled quotes out of two real opinions. He told the court that Kamalthas v. INS held "An adverse credibility determination is not necessarily a death knell to CAT protection." He told the court that Avendano-Hernandez v. Lynch held "The BIA must consider all evidence of record." Neither sentence appears in either opinion. The court read the opinions. The words were not there.

The panel was careful about where the line falls. "The rules are not violated at the point of research and drafting," the order says, "but at the point of signing and filing. If an attorney files a brief with cases or quotations that do not exist, it generally does not matter if he pulled the hallucination from the output of an artificial intelligence tool or from his own natural intelligence." The court noted, almost in passing, that legal AI tools from Westlaw and Lexis "hallucinated 17% and 33% of answers, respectively," to a representative set of queries run in 2024, a point legal observers flagged within hours of the order. The tool was not on trial. The signature was.

And the signature kept making it worse. The court did not sanction Sethi and Rounds for the first bad cite. It sanctioned them for what they did after. "At every subsequent step," the order reads, "including a Motion to Correct, oral argument, the Response to the panel's Order to Show Cause, and more recent filings in other cases, the attorneys knowingly or recklessly made false statements to this Court." The typo story was offered, and held, and repeated. The panel named that as the real offense. "The gravity of discipline we impose, including the temporary suspension of practice, is owed to this repeated failure of candor."

Then it imposed it. Each lawyer was personally sanctioned $2,500, payable in twenty-one days to the Clerk of the US Courts in San Francisco. That number is not the headline. The headline is the next paragraph. "Sethi and Rounds are hereby suspended from practice before this Court for a period of six months starting ten days after this Order is filed." On top of the suspension, every attorney at the firm must, for the next two years, file a statement under penalty of perjury in every filing, disclosing whether and how AI was used.

Other courts have fined lawyers for fake citations. The Ninth Circuit took the bar card.

For half a year, in the largest federal circuit in the country, neither lawyer can file. Two cases that were never real put them out.