The California Court of Appeal, Fourth Appellate District, Division One, has issued a ruling that serves as a cautionary tale for attorneys increasingly relying on artificial intelligence (AI) in their legal practice. The court found that attorney LeRoy George Siddell violated several professional conduct rules by submitting a legal brief riddled with inaccuracies, including fabricated case citations and misrepresentations of existing law. As a result, Siddell was sanctioned and ordered to pay a fine.
The Errors in Question
The case involved an appeal by Raziel Ruiz Alvarez. During the proceedings, Attorney Siddell filed an opposition to a motion to dismiss on behalf of Alvarez. However, the court discovered several significant errors in Siddell’s filing.
First, the brief included a quotation attributed to the case *In re Benoit* (1973), but the quote could not be found in the actual case. Siddell later admitted he had modified the quote to incorporate broader principles.
Second, a case cited, *People v. Robinson* (2009) 172 Cal.App.4th 452, did not exist.
Third, Siddell cited two other cases, *People v. Jones* (2001) 25 Cal.4th 98 and *People v. Williams* (1999) 77 Cal.App.4th 436, but these cases didn’t address the specific legal issues for which they were cited.
The Court’s Response and Attorney’s Admission
The court issued an order to show cause, prompting Siddell to explain why he shouldn’t be sanctioned for these errors. The court cited violations of the Business & Professions Code, the State Bar Rules of Professional Conduct, and the California Rules of Court, all of which outline an attorney’s duty of candor and accuracy.
In response, Siddell admitted to his “lack of professionalism” and acknowledged that he failed to verify the legal citations and sources provided to him by AI. He explained that he had taken courses on AI and was aware that AI could generate inaccurate or “hallucinated” cases, but he did not double-check the information. He admitted he relied on staff to help draft motions and briefs, but recognized it was his responsibility to check the caselaw before submitting documents to the court. He also stated that he would “trust but verify” research provided through the use of AI in the future.
The court accepted Siddell’s subsequent motion to withdraw as counsel, and new counsel was appointed to represent Alvarez.
The Legal Standards and the Court’s Reasoning
The court’s opinion emphasized the importance of attorneys adhering to the legal and ethical standards of their profession. The court cited several key provisions:
* Business & Professions Code section 6068, subdivision (d): This section requires attorneys “to employ . . . those means only as are consistent with truth, and never to seek to mislead the judge or any judicial officer by an artifice or false statement of fact or law.”
* Rules of Professional Conduct, rule 3.3(a)(1) and (2): These rules prohibit attorneys from knowingly making false statements of fact or law to a tribunal or misquoting legal authorities.
* California Rules of Court, rule 8.1115(a): This rule prohibits attorneys from citing opinions that are not certified for publication.
The court referenced a recent case, *Noland v. Land of the Free, L.P.* (Sept. 12, 2025), which discussed the impact of the improper use of AI in legal practice. The court agreed with the *Noland* court’s position that while AI can be used appropriately, attorneys must still verify the accuracy of all citations and ensure that cases are cited for the correct legal propositions. The court underscored that attorneys cannot delegate this responsibility to technology.
The court further noted that the errors in Siddell’s brief were particularly concerning because they involved the rights of a criminal defendant, who is entitled to due process and competent legal representation. The court emphasized that criminal defense attorneys have a heightened duty to ensure the accuracy of their legal arguments, as their failures can undermine the integrity of the judicial system and potentially harm their clients.
The Sanction
As a result of Siddell’s violations, the court imposed a monetary sanction of $1,500. The court stated that this sanction was intended to deter future improper behavior and to reimburse the court for the time and resources expended in addressing the issues. The court directed the Clerk of the court to notify the State Bar of the sanctions against Attorney Siddell.
The Broader Implications
This ruling serves as a clear message to the legal community about the responsibilities that come with using AI in legal practice. While AI tools can assist with research and drafting, attorneys remain ultimately responsible for the accuracy and integrity of their work. The court’s decision emphasizes the importance of verifying all information generated by AI and ensuring that it complies with ethical and professional standards. This case highlights the need for attorneys to be diligent in their use of technology and to prioritize accuracy and truthfulness in all court filings.