From LNU v. Bondi, released Nov. 4, 2025 by Ninth Circuit Judges Richard Paez, Carlos Bea, and Danielle Forrest (though note that, on the merits, the court ruled in petitioners' favor):
On behalf of Petitioners, Attorney Mike Singh Sethi filed an opening brief with multiple fabricated citations and quotations. Sethi cited two cases that do not exist: Eduardo v. Garland, 28 F.4th 742 (9th Cir. 2022), cited at pages 5 and 16 of Petitioners' opening brief, and Lay v. Holder, 729 F.3d 962 (9th Cir. 2013), cited and discussed at page 16. And Sethi twice attributed quotations to opinions in which the quoted language does not appear: Kamalthas v. INS, 251 F.3d 1279, 1284 (9th Cir. 2001), at page 17 of the opening brief, and Avendano-Hernandez v. Lynch, 800 F.3d 1072, 1080 (9th Cir. 2015), at page 19.
After the panel denied the parties' joint motion to submit this case on the briefs, Sethi filed a motion to correct the record regarding errata in the opening brief. That motion represented the two nonexistent cases—Eduardo v. Garland and Lay v. Holder—as typographical errors. Sethi sought to replace those cases with two cases that have similar names, entirely different reporter numbers, and in the case of Lay, a different year and a different holding. Both replacement cases either do not support or are weak support for their intended propositions. The motion does not explain how such significant typographical errors occurred.
Sethi did not appear for oral argument. Attorney William Rounds appeared on behalf of Petitioners instead. At oral argument, confronted with the above issues, Rounds at first insisted that artificial intelligence was not used to draft Petitioners' briefs and that the errors were typographical. He later conceded that artificial intelligence might have been used by the individual who drafted the briefs, and that said individual was not yet licensed to practice law. Since oral argument, we have identified further issues in Petitioners' reply brief, and we have identified at least two other opening briefs filed in pending cases in which Sethi cites cases that do not exist.
