# Del Biaggio v. Bansen: Lawyers Must Cite-Check AI, Not Staff

> A California appeals court says the lawyer, not a paralegal, must verify AI citations before filing. Here is what Del Biaggio v. Bansen now demands of you.

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# Del Biaggio v. Bansen: Why Cite-Checking AI Is the Lawyer's Job, Not the Paralegal's
On July 10, 2026, the California Court of Appeal published Del Biaggio v. Bansen and drew a line that every firm using AI should read twice. In the same opinion, the court held that paralegal fees are recoverable as attorney fees, recognizing paralegals as skilled legal workers, and held that the lawyer, not the paralegal, must cite-check AI: a lawyer must personally review the citations an AI tool produces before a brief is filed. It sanctioned the appellant's counsel $1,500 for filing an opening brief with fictional quotations he had delegated to his paralegal to check.

By [Jamie Kloncz](https://rankshieldlegal.com/about/), Founder, RankShield ** 21 min read ** Published August 22, 2026

When an AI tool drafts a citation, who has to check it before it reaches the court? After Del Biaggio v. Bansen, the answer in California is settled: the lawyer must cite check AI output personally, and handing that job to a paralegal does not satisfy the duty. The Court of Appeal, First Appellate District, Division Four, certified the decision for publication on July 10, 2026, which makes it binding guidance rather than one more cautionary trial-court order [[1]](#ref-1). The court quoted the State Bar's own guidance that "a lawyer must review all outputs produced using AI tools for accuracy, including but not limited to analysis and citations to authority before submission to the court" [[2]](#ref-2).
The facts are almost too neat. The appellant's counsel, Carlton Floyd, added quotations to an opening brief during recesses in another trial and asked his paralegal to verify them. She believed he had already done so. The quotations were fictional. The court reversed the trial court's exclusion of paralegal fees in the same breath that it refused to let a paralegal carry the verification duty, a pairing that tells you exactly where the profession now draws the line between delegable work and non-delegable responsibility.
This article explains what Del Biaggio actually held, why the delegation plan failed even setting the miscommunication aside, where the duty sits in the rules, and a verification workflow a signing lawyer can run without re-researching the brief. It is written from the perspective of a verification vendor, not a law firm, and it is informational rather than legal advice. Every quotation below is drawn from the published opinion or the State Bar guidance it cites, and is attributed accordingly. Del Biaggio is a California decision; lawyers in other states should confirm their own jurisdiction's supervision and candor rules with a licensed attorney, though the Model Rule principles it applies are widely adopted.

## What Del Biaggio v. Bansen actually held
Del Biaggio v. Bansen (Cal. Ct. App., 1st Dist., Div. 4, July 10, 2026) made two rulings that matter here. First, paralegal fees are recoverable under a contract authorizing "attorneys' fees," reversing their categorical exclusion. Second, a lawyer must personally review AI-generated citations before filing; delegating that check to a paralegal does not meet the duty. Counsel was sanctioned $1,500 for fictional quotations [[1]](#ref-1).
The underlying dispute was a contract case. Daniel Del Biaggio won a $52,850 jury verdict against Pete and Mary Ann Bansen over a dairy-succession agreement, then sought $115,533 in attorney fees, including 86.1 hours of paralegal time. The trial court reduced the lawyer's hours and excluded all paralegal fees on the ground that the contract's "attorneys' fees" language did not reach them [[1]](#ref-1).
On appeal, the court reversed that exclusion. It held that fees for paralegal work are recoverable as a component of attorney fees under the contract's fee-shifting provision, consistent with a long line of California authority treating paralegal time as compensable legal work. That holding matters to the AI question because it establishes what a paralegal is: a skilled contributor whose billable work the law recognizes and pays for.
Then the court addressed the appellant's opening brief, which "rested in part on fictional quotations from the case law." It rejected the argument that the appeal was frivolous, but ordered Del Biaggio's counsel to pay a sanction to the court for the misstatements. The recognition of paralegal value and the refusal to let a paralegal shoulder the lawyer's verification duty sit side by side in the same opinion, and that is the point worth holding onto.

## Why delegating the cite check to a paralegal failed the test
The court found the delegation plan improper on its own terms, apart from the miscommunication. Counsel intended to have his paralegal "simply check the citations before filing the brief." The court wrote that this "plan would have been inappropriate even if it had not gone awry," because the State Bar guidance places the review duty on the lawyer, and reading the cited authorities is a fundamental attorney obligation [[1]](#ref-1) [[2]](#ref-2).
Floyd's declaration said his office uses generative AI "consistent with State Bar guidance," with "protocols requiring human verification of all outputs using primary sources." The court took that claim apart. Even if his paralegal had caught the additions, the protocol he described did not comply with the guidance he cited, which requires that a lawyer, not any human, review AI outputs before they reach the court [[2]](#ref-2).
The court was blunt about the arrangement. It gleaned from the declaration that Floyd "used generative AI to make additions to the opening brief during trial recesses in another case without ever planning to review personally, or even to have any other lawyer review, the case law he added." His plan was to have the paralegal check the citations. Being in trial, and therefore unavailable to supervise, made it "even less appropriate for him to expect his paralegal to assume responsibility for verifying what he wrote about cases he apparently had not laid eyes on himself."
There was also a signal the court thought he should have caught: the AI-supplied quotations articulated the exact proposition he wanted, "including purportedly from the California Supreme Court 26 years ago," yet had eluded him when he researched the same issue at trial. A source that appears only when a tool conjures it, and never in your own research, is a red flag, not a gift.
The sanction here rests on existing duties of candor and competent supervision, not on any new AI-specific rule. Del Biaggio applies the State Bar's Practical Guidance and long-standing authority; it does not announce a novel certification requirement.

Source: Del Biaggio v. Bansen, No. A174647 (Cal. Ct. App. 2026) Download SVG

## Where the verification duty sits in the rules
The duty flows from the lawyer's candor and supervision duties, not a special AI rule. Rule 3.3(a)(1) forbids failing to correct a false statement of law made to a court. The State Bar guidance and Noland v. Land of the Free establish that reading the authorities you cite, to confirm they stand for what you claim, is a fundamental duty that AI does not shift onto staff [[2]](#ref-2) [[3]](#ref-3) [[4]](#ref-4).
The court anchored the reading duty in Noland v. Land of the Free, L.P. (2025), quoting its statement that "it is a fundamental duty of attorneys to read the legal authorities they cite in appellate briefs or any other court filings to determine that the authorities stand for the propositions for which they are cited" [[4]](#ref-4). That duty predates generative AI by decades. It applied to associates, to commercial research services, and now to model output, without changing shape.
The candor duty carried its own weight in the sanction. The State Bar guidance, quoted by the court, requires counsel to "correct any errors or misleading statements made to the court, regardless of whether such outputs were generated with or without real-time human direction," which the court paired with Rule 3.3(a)(1) [[2]](#ref-2) [[3]](#ref-3). Floyd eventually filed a letter withdrawing the misstatements, but it came only days before oral argument and more than three months after the opposing motion put him on notice. The court rejected his claim that the delay caused no prejudice.
Read together, the rules describe a chain that always ends at the signing lawyer. A paralegal can research, draft, and format, and the firm can bill for that work. What the lawyer cannot delegate is the certification that the authorities are real, accurately quoted, and still good law. That is the specific act Del Biaggio protects.

## The pairing that makes this opinion unusual
Most AI-sanctions opinions do one thing: they punish a lawyer for unverified output. Del Biaggio does two, and they point in opposite directions. It expands what a firm can recover for paralegal work, holding 86.1 hours of paralegal time compensable under a contract's "attorneys' fees" clause, while simultaneously refusing to let a paralegal carry the verification duty [[1]](#ref-1).
It would be easy to read the verification holding as a demotion of paralegals. The opinion says the opposite, and it says it first. The court reversed the trial court's categorical exclusion of paralegal fees, holding that work billed by paralegals is recoverable as a component of attorney fees. The firm had sought $115,533 in fees including 86.1 hours of paralegal time, and the trial court had zeroed that component entirely on the theory that "attorneys' fees" means fees for attorneys [[1]](#ref-1).
That reversal is a statement about what paralegal work is worth. The law treats it as skilled legal labor that a paying party can be ordered to reimburse. A court that thought paralegals were clerical would not have written that half of the opinion.
So the verification holding is not about competence or status. It is about who signs. The signature on a brief is a certification, and a certification can only be made by the person whose name is on it. That is why the same court can say, in one opinion, that a paralegal's 86.1 hours are worth real money and that a paralegal cannot perform the lawyer's final read.
The practical consequence for a firm is a clean division rather than a restriction. Paralegal time spent assembling a verification record is billable, recoverable work that strengthens the file. The lawyer's read on top of it is the part that cannot be moved. A firm that structures its workflow that way loses nothing economically and gains the one thing Del Biaggio actually demands.

## Who gets sanctioned when an AI citation is fabricated
The signing lawyer does. Del Biaggio ordered counsel to pay $1,500 to the court for the fictional quotations [[1]](#ref-1). It sits in a growing California line: People v. Alvarez imposed $1,500 for a fictitious quotation and a nonexistent case, and Schlichter v. Kennedy imposed $1,750 for fabricated authority where the court found denials of AI use not credible [[1]](#ref-1).
The dollar figures are modest; the pattern is not. The Del Biaggio court cited its own recent authority in a single string: Alvarez at $1,500, Schlichter at $1,750, and [the Ninth Circuit's LNU v. Blanche](https://rankshieldlegal.com/blog/ninth-circuit-ai-sanctions-precedent), which sanctioned two attorneys $2,500 each for briefs with "multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases" and then denying that AI might have produced the errors [[1]](#ref-1). Public trackers such as the Damien Charlotin AI Hallucination Cases database catalog well over a thousand United States filings involving AI-fabricated or misused citations as of mid-2026, a count best read as approximate and rising [[6]](#ref-6).
Notice what draws the sanction in each case. It is not that a tool was used. It is that unverified output reached the court under a lawyer's name, and, in several instances, that the lawyer was slow or less than candid about the failure once it surfaced. Alvarez and Schlichter both turned on unverified AI citations; Del Biaggio added the delegation wrinkle and the delayed correction.
For a signing attorney, the takeaway is that the reputational cost now outruns the monetary one. A published opinion naming you, quoting your fictional citations, and explaining that your verification protocol was inadequate is a durable record. The way to stay out of that line is not to avoid AI. It is to make the lawyer's verification real and provable.
Case Court Sanction What triggered it
Del Biaggio v. Bansen (2026) Cal. Ct. App., 1st Dist. $1,500 to the court Fictional quotations; cite check delegated to a paralegal [1]
People v. Alvarez (2025) Cal. Ct. App. $1,500 Fictitious quotation and a nonexistent case; AI used without verification [1]
Schlichter v. Kennedy (2025) Cal. Ct. App. $1,750 Fabricated authority; denials of AI use found not credible [1]
LNU v. Blanche (2026) 9th Cir. $2,500 each Nonexistent cases and misattributed quotations; denied AI involvement [1][7]

## The correction clock: why the delay cost more than the error
Del Biaggio was not sanctioned only for filing fictional quotations. The court weighed the fact that counsel withdrew the misstatements just days before oral argument, more than three months after the opposing sanctions motion put him on notice, and it rejected his argument that the delay caused no prejudice [[1]](#ref-1).
There are two failures in this case, and firms tend to fixate on the first. The first is that unverified AI output reached a filing. The second is what happened in the three months after someone pointed it out. The court treated both as sanctionable, and the second is the one entirely within a lawyer's control after the fact.
The State Bar guidance the court quoted is explicit that counsel must "correct any errors or misleading statements made to the court, regardless of whether such outputs were generated with or without real-time human direction" [[2]](#ref-2). Paired with Rule 3.3(a)(1), which forbids failing to correct a false statement of law to a tribunal, the duty does not wait for a convenient moment [[3]](#ref-3).
Floyd did eventually file a letter withdrawing the misstatements. The timing is what the court noticed: days before argument, after more than three months of notice. He argued the delay produced no prejudice. The court disagreed, and the sanction covers both the misstatements and the failure to correct them promptly [[1]](#ref-1).
This reframes what a firm's AI incident response has to do. Discovering a fabricated citation in your own filed brief is bad but survivable. Sitting on it converts a verification failure into a candor problem, and candor problems are the ones that generate published opinions with your name in them. The correct move on discovery is immediate written notice to the court and opposing counsel, before anyone has to ask twice.
It is worth noting what the court did not do. It rejected the argument that the appeal was frivolous and vacated a separate trial-court sanction [[1]](#ref-1). This was not a court looking for reasons to punish. It sanctioned the specific conduct it found culpable: fictional authority, an inadequate verification plan, and a slow correction.

- **Stop and confirm the defect yourself** Read the authority in question personally. Do not accept a staff report or a tool's second opinion as the finding. You are about to make a representation to a court about your own filing.
- **Notify the court and opposing counsel in writing, immediately** The duty under Rule 3.3(a)(1) and the State Bar guidance runs from the moment you know. Del Biaggio shows that a correction filed months later, on the eve of argument, does not read as diligence.
- **State plainly what happened and how** The Ninth Circuit in LNU v. Blanche sanctioned attorneys who denied AI involvement, and Schlichter v. Kennedy involved denials the court found not credible. Candor about the cause is treated better than a narrow correction that obscures it [[1]](#ref-1) [[7]](#ref-7).
- **Re-verify the entire filing, not just the flagged citation** One fabricated authority in a brief is evidence about the process that produced the brief. Run the three checks across every cited authority before you represent that the filing is now clean.
- **Record what you fixed and when** The remediation record is what answers the court's next question. A verification log that shows who re-checked each authority and on what date turns an assertion into something you can hand over.

## A verification workflow a signing lawyer can actually run
Personal verification is not re-researching the brief. For every cited authority, the signing lawyer confirms three things: that it exists and is correctly identified, that the quotation and characterization are accurate, and that it is still good law. A paralegal can prepare and organize this record; the lawyer performs and attests to the final review [[2]](#ref-2) [[4]](#ref-4).
The phrase "the lawyer must review" sounds like a demand to redo everything. It is narrower than that. The reading duty in Noland asks the signer to confirm, for each authority, three specific things, the same core checks in our guide on [verifying AI-generated case citations before you file](https://rankshieldlegal.com/blog/verify-ai-case-citations-before-filing), and to be able to show that the confirmation happened.
First, existence and identity: the case, statute, or rule is real and cited correctly. A fabricated authority fails here before any question of what it holds. Second, accuracy: the brief says what the source actually says, not what a model asserted it says. Reliability research underscores why this cannot be skipped; a Stanford study of leading legal AI research tools found inaccurate answers on a meaningful share of queries, with figures reported around 17 percent for one product and 33 percent for another in 2024 testing [[5]](#ref-5). Third, good law: the authority has not been overruled, reversed, or superseded.
The delegation line from Del Biaggio maps cleanly onto this. A paralegal can pull the sources, assemble the pincites, run the citator, and hand the lawyer an organized packet. The lawyer reads the authorities, confirms the three checks, and signs. What Del Biaggio forbids is the lawyer skipping that read and treating the paralegal's pass as the certification. This is where a verification system earns its place: RankShield Legal certifies which cited authorities exist, are quoted accurately, and remain good law, and records who ran the final review and when, so the lawyer's verification is not just performed but provable if a court asks.
3 checks what the signing lawyer confirms for every authority: it exists, it is quoted accurately, and it is still good law [4]

## What this means if you do not practice in California
Del Biaggio binds California courts. Its reasoning travels further, because it rests on duties that are not California-specific: the duty to read what you cite, and the duty to correct false statements of law. The Ninth Circuit reached the same place in LNU v. Blanche, sanctioning two attorneys $2,500 each and suspending them for six months [[1]](#ref-1) [[7]](#ref-7).
The holding is jurisdictionally limited and this article does not suggest otherwise. A lawyer in Texas or New York is not governed by a California Court of Appeal decision, and any specific question about a state's supervision rules belongs with a licensed attorney in that state.
What travels is the structure of the reasoning. Del Biaggio did not invent an AI rule. It applied the duty to read the authorities you cite, drawn from Noland, and the duty of candor under Rule 3.3(a)(1) [[3]](#ref-3) [[4]](#ref-4). Both are versions of Model Rules adopted in substantially similar form across the great majority of United States jurisdictions. A court elsewhere reaching this question is likely to reach for the same two duties, because they are the ones that fit.
The federal picture points the same direction. The Ninth Circuit's decision in LNU v. Blanche, published and precedential, sanctioned two attorneys $2,500 each, suspended them from practice before the court for six months, and required disclosure of generative AI use in future filings [[1]](#ref-1) [[7]](#ref-7). That is a materially heavier consequence than California's $1,500, reached through the same logic about unverified authority and lack of candor.
The volume question settles the rest. Public trackers catalog well over a thousand United States filings involving AI-fabricated or misused citations as of mid-2026 [[6]](#ref-6). A firm waiting for its own jurisdiction to publish an opinion before changing its workflow is betting that it will not be the case that generates one.
The practical posture, then, is the same everywhere: treat the signing lawyer's read as non-delegable, treat a discovered error as an immediate correction obligation, and keep a record that shows both happened. None of that depends on which state's opinion you are reading.

Test yourself
## Test yourself on the delegation line
Five questions on what Del Biaggio asks of the lawyer who signs the brief.

- 1 Why did the court reject counsel's plan to have his paralegal check the citations? Because the paralegal was not qualified Because the State Bar guidance places the review duty on a lawyer Because the brief was filed late **Answer:** Because the State Bar guidance places the review duty on a lawyer The court held the plan "would have been inappropriate even if it had not gone awry." The guidance requires that a lawyer, not merely a human, review AI outputs before submission. It was about who signs, not about the paralegal's competence.
- 2 What did the same opinion hold about paralegal fees? They are not recoverable as attorney fees They are recoverable, reversing a categorical exclusion The court did not address them **Answer:** They are recoverable, reversing a categorical exclusion The court reversed the trial court's exclusion of all 86.1 hours of paralegal time, holding such fees recoverable under a contract authorizing attorneys' fees. The opinion recognizes paralegal value and refuses the delegation in the same breath.
- 3 Besides the fictional quotations, what else did the court weigh in imposing the sanction? The size of the underlying verdict The delay in correcting the misstatements The number of briefs filed **Answer:** The delay in correcting the misstatements Counsel withdrew the misstatements only days before oral argument, more than three months after the opposing motion put him on notice. The court rejected his claim that the delay caused no prejudice and sanctioned both the misstatements and the slow correction.
- 4 Did Del Biaggio create a new AI-specific rule? Yes, a new certification requirement No, it applied the existing duties to read cited authority and to correct false statements Yes, a mandatory AI disclosure rule **Answer:** No, it applied the existing duties to read cited authority and to correct false statements The court applied the fundamental duty to read the authorities you cite, from Noland v. Land of the Free, and the candor duty under Rule 3.3(a)(1). It treated AI output the way it would treat reliance on an associate or a research service.
- 5 What signal did the court suggest counsel should have caught? The brief exceeded the page limit The quotations stated exactly the proposition he wanted but had never surfaced in his own research The paralegal flagged a concern **Answer:** The quotations stated exactly the proposition he wanted but had never surfaced in his own research The AI-supplied quotations articulated the precise proposition counsel needed, including one purportedly from the California Supreme Court 26 years earlier, yet had eluded him when he researched the same issue at trial. Authority that appears only when a tool produces it is a red flag.
Honest self-check. There is no sign-up, and nothing is stored.

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- **Does Del Biaggio v. Bansen require the lawyer, not a paralegal, to check AI citations?** Yes. The California Court of Appeal held that a lawyer must personally review AI-generated outputs, including citations, before a brief is filed, and that a plan to have a paralegal "simply check the citations" was inappropriate even apart from the miscommunication that occurred. The court quoted the State Bar guidance that "a lawyer must review all outputs produced using AI tools for accuracy" before submission. A paralegal can prepare and organize the verification record, but the signing lawyer performs and attests to the final review. The decision was certified for publication on July 10, 2026, which makes it binding guidance in California rather than an isolated trial-court order.
- **What was the sanction in Del Biaggio v. Bansen?** The court ordered the appellant's counsel, Carlton Floyd, to pay a $1,500 sanction to the court for filing an opening brief that rested in part on fictional quotations from case law. The court rejected the argument that the appeal was frivolous and vacated a separate trial-court sanction, but imposed the $1,500 sanction specifically for the misstatements and for the failure to correct them promptly. The correction came only days before oral argument, more than three months after the opposing sanctions motion put counsel on notice, and the court rejected the claim that the delay caused no prejudice.
- **Did Del Biaggio create a new AI-specific rule for lawyers?** No. The court applied existing duties. The verification obligation flows from the fundamental duty to read the authorities you cite, stated in Noland v. Land of the Free, and from the duty of candor, which requires correcting false statements of law under Rule of Professional Conduct 3.3(a)(1). The court also quoted the State Bar's Practical Guidance for the Use of Generative Artificial Intelligence in the Practice of Law. None of this is a new certification requirement; it is the application of long-standing candor and supervision duties to AI output, which the court treated the same way it would treat reliance on an associate or a commercial research service.
- **Can a paralegal do any part of AI citation verification?** Yes, and Del Biaggio confirms paralegals do valuable legal work; the same opinion held that paralegal fees are recoverable as attorney fees. A paralegal can locate the cited sources, assemble pincites and quotations, run a citator to check whether authority is still good law, and organize the results for review. What a paralegal cannot do is substitute for the lawyer's own reading and certification. The court drew the line at the signing lawyer relying on the paralegal's pass instead of personally confirming that the authorities exist, are quoted accurately, and remain good law before the brief is filed.
- **How should a firm verify AI-generated citations without redoing the research?** Run three checks on every cited authority: confirm it exists and is identified correctly, confirm the quotation and characterization match the actual source, and confirm it is still good law. Reading research supports why accuracy cannot be assumed; leading legal AI tools returned inaccurate answers on a meaningful share of queries in 2024 testing, so fluent output is not reliable output. Structure the work so a paralegal prepares the record and the signing lawyer performs the final review and can show it happened. A verification system that certifies which citations are real and records who reviewed them turns that duty into something you can prove, not just assert.
- **What should a lawyer do after discovering a fabricated citation in a filed brief?** Correct it immediately and in writing. Del Biaggio sanctioned counsel for the misstatements and for failing to correct them promptly; the withdrawal came days before oral argument, more than three months after the opposing sanctions motion put him on notice, and the court rejected the argument that the delay caused no prejudice. The State Bar guidance requires correcting errors or misleading statements made to the court regardless of how the output was generated, and Rule 3.3(a)(1) forbids failing to correct a false statement of law. Confirm the defect personally, notify the court and opposing counsel, be candid about the cause rather than obscuring it, re-verify every other authority in the filing, and keep a record of what was re-checked and when.
- **Does Del Biaggio apply outside California?** Not as binding authority. It is a California Court of Appeal decision and governs California courts; lawyers elsewhere should confirm their own jurisdiction's rules with a licensed attorney in that state. Its reasoning, however, rests on duties that are not California-specific: the fundamental duty to read the authorities you cite and the duty of candor toward a tribunal, both of which exist in substantially similar form across most United States jurisdictions. The Ninth Circuit reached the same conclusion in LNU v. Blanche, imposing $2,500 on each of two attorneys, suspending them from practice before the court for six months, and requiring disclosure of generative AI use in future filings. The direction of travel is consistent across courts.

## References

- Court of Appeal of California, First Appellate District, Division Four. Del Biaggio v. Bansen, No. A174647 (certified for publication). July 2026. [https://storage.courtlistener.com/pdf/2026/07/10/del_biaggio_v._bansen.pdf](https://storage.courtlistener.com/pdf/2026/07/10/del_biaggio_v._bansen.pdf)
- State Bar of California, Standing Committee on Professional Responsibility and Conduct. Practical Guidance for the Use of Generative Artificial Intelligence in the Practice of Law. 2026. [https://www.calbar.ca.gov/Portals/0/documents/ethics/Generative-AI-Practical-Guidance.pdf](https://www.calbar.ca.gov/Portals/0/documents/ethics/Generative-AI-Practical-Guidance.pdf)
- State Bar of California. Rules of Professional Conduct, rule 3.3(a)(1). 2026. [https://www.calbar.ca.gov/Portals/0/documents/rules/Rule_3.3-Exec_Summary-Redline.pdf](https://www.calbar.ca.gov/Portals/0/documents/rules/Rule_3.3-Exec_Summary-Redline.pdf)
- Court of Appeal of California. Noland v. Land of the Free, L.P. (2025) 114 Cal.App.5th 426. 2025. [https://law.justia.com/cases/california/court-of-appeal/2025/b331918.html](https://law.justia.com/cases/california/court-of-appeal/2025/b331918.html)
- Stanford HAI. AI on Trial: Legal Models Hallucinate in 1 out of 6 (or More) Benchmarking Queries. 2024. [https://hai.stanford.edu/news/ai-trial-legal-models-hallucinate-1-out-6-or-more-benchmarking-queries](https://hai.stanford.edu/news/ai-trial-legal-models-hallucinate-1-out-6-or-more-benchmarking-queries)
- Damien Charlotin. AI Hallucination Cases Database. 2026. [https://www.damiencharlotin.com/hallucinations/](https://www.damiencharlotin.com/hallucinations/)
- U.S. Court of Appeals for the Ninth Circuit. LNU v. Blanche, No. 24-4790 (9th Cir. June 3, 2026) (published). June 2026. [https://cdn.ca9.uscourts.gov/datastore/opinions/2026/06/03/24-4790.pdf](https://cdn.ca9.uscourts.gov/datastore/opinions/2026/06/03/24-4790.pdf)

Written by
## [Jamie Kloncz](https://rankshieldlegal.com/about/)
Founder, RankShield
Jamie Kloncz is the founder of RankShield, the verifiable AI and quantum security platform behind RankShield Legal. An engineer by training, he built RankShield after his own devices and business were attacked, including an AI voice-cloning scam that targeted his family, on one conviction: unverifiable security is the real danger, so every consequential action should leave a receipt anyone can independently check.
[More about Jamie →](https://rankshieldlegal.com/about/)

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