Jose Luis Nazar and Land of the Free own an office building located at 640 S. San Vicente Boulevard (the San Vicente property) and an event space located at 2400 Laurel Canyon Boulevard in Los Angeles (the Laurel Canyon property) L.P.

Sylvia Noland was hired hired to work as their leasing agent and sales representative. She filed a lawsuit in August 2018 asserted 25 causes of action, including violations of California’s wage and hour laws, constructive and wrongful termination and other employment law related claims.

The trial court granted defendants’ motion for summary judgment, finding no triable issues as to any of those claims. Among other things, the court found the evidence was undisputed that (1) plaintiff was an independent contractor, not an employee, and thus the wage and hour laws did not apply to her, (2) defendants did not owe plaintiff a commission because the tenant plaintiff said she secured ultimately did not execute a lease with defendants, (3) plaintiff had not demonstrated that she was subject to any adverse employment actions that could form the basis for a retaliation action, and (4) plaintiff did not demonstrate triable issues as to her intentional infliction of emotional distress claim.

On July 25, 2023, plaintiff filed a notice of appeal from the order granting summary judgment and challenges the grant of summary judgment on several grounds. On appeal she was represented by Mostafavi Law Group and Amir Mostafav located in Los Angeles.

The judgment was affirmed. Attorney Amir Mostafavi was directed to pay $10,000 in sanctions in the published case of Noland v. Land of the Free, L.P. -B331918 (September 2025). Relevant excerpts from the opinion are quoted below.

“Prior to oral argument in this case, on our own motion we issued an order to show cause (OSC) why this court should not sanction plaintiff’s counsel, Amir Mostafavi, for filing appellate briefs replete with fabricated quotes and citations. The OSC noted that nearly all of the quotations in appellant’s opening brief, as well as many in the reply brief, were fabricated, and it warned that sanctions might include both an award of attorney fees and costs to defendants and an award of sanctions payable to the clerk of this court.”

“Attorney Mostafavi filed a written response. He acknowledged that he relied on AI ‘to support citation of legal issues’ and that the fabricated quotes were AI-generated. He further asserted that he had not been aware that generative AI frequently fabricates or hallucinates legal sources and, thus, he did not ‘manually verify [the quotations] against more reliable sources.’ Mostafavi accepted responsibility for the fabrications and said he had since taken measures to educate himself so that he does not repeat such errors in the future.”

“Plaintiff challenges the grant of summary judgment on several grounds, none of which raises any novel questions of law or requires us to apply settled law in a unique factual context. In short, this is in most respects a straightforward appeal that, under normal circumstances, would not warrant publication.”

“What sets this appeal apart – and the reason we have elected to publish this opinion – is that 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. These fabricated legal authorities were created by generative artificial intelligence (AI) tools that plaintiff’s counsel used to draft his appellate briefs. The AI tools created fake legal authority – sometimes referred to as AI “hallucinations” – that were undetected by plaintiff’s counsel because he did not read the cases the AI tools cited.”

“Although the generation of fake legal authority by AI sources has been widely commented on by federal and out-of- state courts and reported by many media sources, no California court has addressed this issue. We therefore publish this opinion as a warning. Simply stated, no brief, pleading, motion, or any other paper filed in any court should contain any citations – whether provided by generative AI or any other source – that the attorney responsible for submitting the pleading has not personally read and verified. Because plaintiff’s counsel’s conduct in this case violated a basic duty counsel owed to his client and the court, we impose a monetary sanction on counsel, direct him to serve a copy of this opinion on his client, and direct the clerk of the court to serve a copy of this opinion on the State Bar.”