People v. Alvarez

Summary

The California Court of Appeal addresses an attorney’s failure to verify artificial-intelligence-generated legal citations and quotations in a criminal appeal. The court finds violations of professional and court rules, publishes the order, imposes a $1,500 sanction payable by the attorney, and directs notice to the State Bar. New counsel was appointed after the attorney withdrew from representing the defendant.

Holdings

1. An attorney may appropriately use artificial intelligence in law practice, but must personally verify every legal citation, ensure that cited cases exist, confirm that citations are accurate, and ensure that authorities support the propositions for which they are cited. This responsibility cannot be delegated to technology.
2. Siddell violated his professional duty by submitting a hallucinated citation and misrepresenting the law stated in other opinions; he also violated California Rules of Court rules 8.1115(a) and 8.276(a)(4).
3. Because counsel violated a Rule of Professional Conduct, the court was required to take appropriate corrective action and properly imposed a $1,500 sanction payable personally by Siddell to the Fourth District Court of Appeal, Division One, and directed notice to the State Bar.

Questions Presented

1. Whether counsel violated California's professional-conduct rules and Rules of Court by filing a fabricated quotation, citing a nonexistent case, and misrepresenting the holdings or substance of other authorities.
2. Whether the court should impose a monetary sanction and take other corrective action for those violations.
3. Whether counsel's use of artificial intelligence relieved him of his professional duty to verify legal authorities.

Disposition

other