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The sanctions record · U.S. Court of Appeals, Fourth Circuit, 2026

In re: Eric Chibueze Nwaubani

No. 25-9517 (4th Cir. Standing Panel on Attorney Discipline) · unpublished per curiam opinion of Quattlebaum, Rushing and Benjamin, JJ., submitted 13 January 2026, decided 11 March 2026

Page verified 5 August 2026. Quotations are from the court’s own unpublished opinion, linked below.

The discipline track, not the sanctions track. A dedicated circuit disciplinary panel, with its own prosecuting counsel, took over after a merits panel found a citation to a Supreme Court decision that does not exist. The penalty was a public admonishment for violating the circuit’s own local rule.

The timeline

  • 2023–2025Nwaubani represents the plaintiff on appeal in Bolden v. Baltimore Gas and Electric Co., No. 23-2195, an employment discrimination appeal.
  • During briefingThe merits panel discovers that Nationwide Mutual Insurance Co. v. Jackson, 548 U.S. 629 (2006), cited in the brief, does not exist. It orders a revised brief and a show-cause response.
  • ResponseNwaubani denies using generative AI and says he meant to cite Nationwide Mutual Insurance Co. v. Darden, 503 U.S. 318 (1992), an ERISA case. His revised brief drops the argument and does not cite Darden at all.
  • 9 May 2025Bolden is decided, 2025 WL 1355304.
  • 11 Mar 2026The Standing Panel on Attorney Discipline issues a public admonishment.

What the AI did

As in Whiting, the court makes no finding that a particular tool produced the citation, and we do not assert one. What the record shows is a brief containing nonexistent judicial opinions, an explanation the panel did not accept, and a revised brief that quietly abandoned the argument the explanation had been offered to justify.

What the court did, and why

The panel found a violation of Fourth Circuit Local Rule 46(g)(1)(c) and imposed a public admonishment. Two structural features matter more than the penalty:

  • A standing panelThe Fourth Circuit runs a permanent Standing Panel on Attorney Discipline. This was not the merits panel improvising a remedy; it was a separate disciplinary proceeding with its own docket number.
  • Prosecuting counselThe Office of Disciplinary Counsel appeared against the attorney. Once a matter reaches this track, it is adversarial.
  • On the record“Public admonishment” means the opinion is the penalty. It is findable by any client, opponent or bar admissions officer.

What it changed

This is the case that shows the second door. Rule 11 and inherent-power sanctions are one route; a circuit’s own admissions and discipline rules are another, and the second does not need a motion from an opponent or a live case to run in. It also shows the cost of the denial: the panel proceeded on the conduct, and the unaccepted explanation is now part of the published record of it.

The lesson for the next filing

A denial you cannot evidence is worse than the error it was meant to cover. The only good answer to “did you use AI, and how did you check it?” is a contemporaneous record made at the time, not a reconstruction made under a show-cause order.

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Sources

Related

Checked 5 August 2026 against the court’s own opinion. Unpublished opinions are not binding precedent in the Fourth Circuit, and we say so. Information, not legal advice.

Information, not legal advice. Every entry is verified against the court’s own document or contemporaneous reporting; where a source is reporting rather than the document, we say so.