Noland v. Land of the Free, L.P.
Key Findings
- Opening brief: 13 cited cases could not be verified to exist — including Goldstine v. Liberty Mut. Ins., Caldwell v. Unified Capital Group, Heckert v. MacDonald, Kumar v. Ramsey, Carlton v. Quint, Laabs v. City of Victorville, Scheidler v. Mission Valley Resort, Peake v. Underwood, Regency Health Services, Valdez v. Kismet Acquisition, Schultz v. Harney, Schimmel v. Levin, and Alliance Bank v. Murray — plus a nonexistent Labor Code § 1298 and 13 fabricated quotes.
- Reply brief: 5 additional nonexistent cases — Biles v. Exxon Mobil, Ehrhart v. McKinley, Sentry Ins. v. Superior Court, Royalty Carpet Mills v. City of Irvine, and Rappleyea v. Campbell — plus 5 more fabricated quotes.
- Beyond the fabrications, 13 real cases are cited for propositions the opinions do not support, and 21 additional citations are potentially stretched beyond their holdings.
Court Response
Disposition: Judgment affirmed. $10,000 monetary sanction imposed on attorney Amir Mostafavi (Mostafavi Law Group), payable to the clerk of the court within 30 days of remittitur. The clerk was directed to serve a copy of the opinion on the State Bar of California, and counsel was directed to serve a copy on his client. The court elected to publish the opinion, noting that nothing about the underlying appeal would ordinarily warrant publication — but that "what sets this appeal apart" was the fabricated authority.
The court wrote: "nearly all of the legal quotations in plaintiff's opening brief, and many of the quotations in plaintiff's reply brief, are fabricated. That is, the quotes plaintiff attributes to published cases do not appear in those cases or anywhere else. Further, many of the cases plaintiff cites do not discuss the topics for which they are cited, and a few of the cases do not exist at all." The court calculated that the "opening brief contains 23 case quotations, 21 of which are fabrications." Named examples: Schimmel v. Levin ("does not contain a single reference to either summary judgment or section 437c"), Regency Health Services ("does not address the granting of a continuance, and the quoted language does not appear anywhere in the opinion"), Peake v. Underwood ("does not address the filing of a second dispositive motion"), Goldstine v. Liberty Mut. Ins. ("Goldstine appears to be a fabricated case"), and Heckert v. MacDonald (the quoted "frivolous," "unfair," and "tactics" language "do not appear in Heckert"). Counsel admitted using generative AI to prepare the briefs.
Comparison: Direct match at scale. Opine flagged 18 fabricated cases (13 in the opening brief, 5 in the reply), 1 fabricated statute (Labor Code § 1298), and 18 fabricated quotes across the two briefs. The court independently arrived at the same picture, with its own count of "21 of [23] case quotations" fabricated in the opening brief. Every case the court named by way of example — Goldstine, Heckert, Peake, Schimmel, Regency Health Services, and Rappleyea — appears on Opine's ☠️ list. This is also the opinion other courts in Cite Jail cite when they sanction AI fabrications: the Hall, EFD, Rios, and Gamez decisions all rely on Noland as controlling authority.
Every citation in the filing above was checked against the actual opinion or statute it claimed to cite. Fabricated items could not be verified to exist. Mischaracterized items are real cases described incorrectly. Potentially stretched items are real citations applied in ways that push beyond the holding — judgment calls rather than definitive errors.
Opine's citation verification currently covers California state courts and the 9th Circuit — the jurisdictions where our case-law and statute data is comprehensive.