In the published case of Shayan v. Shakib -B337559 (December 2025) the Court of Appeal issued a strongly worded published order imposing sanctions on appellant’s counsel, Fahim Farivar, for filing an opening brief riddled with fabricated case quotations and an intentionally misleading citation to a hearing transcript from an unrelated case.
According to his firm’s website “Farivar Law Firm, APC is an AV-rated Los Angeles legal firm which has built a strong reputation for aggressive litigation, outstanding results, and attentive service. We combine the many services of a large legal firm with the personal attentiveness of a sole attorney practice.” Farivar has an office at 18321 Ventura Blvd., Suite 750 in Tarzana California.
The respondent moved to strike the brief and dismiss the consolidated appeals, contending that the numerous fictitious quotations were the product of artificial-intelligence “hallucinations.” Appellant and Farivar denied any use of AI, instead attributing the inaccuracies to a flawed internal drafting process in which non-attorney staff were given vague paraphrased “placeholders” and instructed to locate and insert verbatim language from Westlaw. The court found this explanation immaterial: whether the false quotations originated from generative AI or from Farivar’s delegation of critical citation work to unqualified staff, the signatory attorney remained fully responsible for ensuring the accuracy of everything submitted to the court.
The panel identified three categories of fabrications: (1) real words from cited cases rearranged into sentences that never appeared in the opinions; (2) loose paraphrases presented as direct quotations; and (3) wholly invented statements bearing no relation to the cited authority (including one fabricated quotation about attorney fees in a case that never mentioned the topic). The court rejected Farivar’s characterization of these as mere “clerical citation errors,” noting that the opposition papers themselves continued to misrepresent case holdings.
Relying on recent precedent (People v. Alvarez (2025) 114 Cal.App.5th 1115 and Noland v. Land of the Free, L.P. (2025) 114 Cal.App.5th 426), the court held that submitting briefs containing fabricated legal authority constitutes an unreasonable violation of the California Rules of Court and the Rules of Professional Conduct, regardless of the source of the falsehoods. Farivar’s practice of providing staff with placeholder paraphrases and expecting accurate verbatim insertions carried the same inherent risk of error as uncritical reliance on AI tools.
The court declined to grant respondent’s request to dismiss the appeals, finding that sanction short of dismissal would suffice. Instead, it ordered:
– – Monetary sanctions of $7,500 payable by Farivar personally to the clerk of the court within 30 days of remittitur;
– – The original opening brief stricken in its entirety;
– – Appellant granted leave to file a corrected opening brief (with redline) within 10 days, limited to removing or correcting the fabricated material; and
– – A copy of the order forwarded to the State Bar of California for investigation of Farivar’s apparent violation of Rules of Professional Conduct, rule 3.3(a)(2) (prohibiting knowingly misquoting authority).
Emphasizing the broader threat to judicial integrity, the court warned that inaccurate or hallucinated authorities whether generated by technology or human carelessness can be repeated, believed, and eventually treated as established law. The panel declared there is “no room in our court system for the submission of fake, hallucinated case citations, facts, or law.”
The order underscores that, in the era of both generative AI and increasingly complex delegation practices, the ethical and procedural duty of accuracy remains exclusively on the attorney who signs and files the document.