Michael L. Ruiz v. Magellan Financial & Insurance Services

How one brief became four

• 8 Jul 2026An order to show cause issues over two false quotations from Ninth Circuit cases, in a response to a fee application.
• ThenCounsel responds.
• ThenThe court itself identifies three other briefs containing similar errors, and orders counsel to address them.
• ThenCounsel responds again, admitting three briefs containing fabricated AI-generated quotations and a fourth containing an inaccurate AI-generated case summary.
• 24 Aug 2026Order. Formal public reprimand. No monetary penalty.

The opposing party did not surface the pattern. The court did.

The tool, named in counsel’s own words

“In the course of preparing this Motion, Ms. Tate utilized ChatGPT to prepare the draft brief.”

The misused authorities include Ansell v. Green Acres Contracting Co., 347 F.3d 515 (3d Cir. 2003), and misquotations attributed to Antonakeas and Osazuwa.

The rules, and the ladder

The order finds violations, “at a minimum”, of Federal Rule of Civil Procedure 11(b)(2) and of Arizona’s Ethical Rules 1.3 on diligence, 1.1 on competence, and 3.1 on having a good-faith basis in law.

It then applies the ABA Standards for Imposing Lawyer Sanctions as adopted in the Ninth Circuit, quoting In re Girardi, 611 F.3d 1027, 1038 (9th Cir. 2010). Three rungs are in play: standard 6.12, suspension; standard 6.13, reprimand; standard 6.14, admonition. The rung is chosen by mental state.

Mitigating factors found: remorse, and the absence of a dishonest motive. Aggravating factors found: prior discipline, a pattern of misconduct and multiple offences, and substantial experience in the practice of law.

The order

“IT IS ORDERED that this order constitutes a formal public reprimand. Ms. Tate must report this discipline in any context in which she is required to report past instances of attorney discipline.”

The conduct is characterised as “at least negligent” and “arguably reckless”, but not knowingly deceptive. That is why suspension was not reached. The court also concluded that no sanction less severe than a reprimand would be appropriate, which is why admonition was not enough.

The penalty is the publicity and the reporting obligation. There is no fine.

What this case contributes

• The unitThe assessment was not the caught brief. It was the practice, across four briefs, found by the court’s own search.
• The ladderAn explicit mapping of AI misuse onto suspension, reprimand and admonition, decided by mental state.
• No moneyThe sanction is a professional record and a reporting duty, not money. It follows counsel to every future admission and renewal.
• ExperienceSubstantial experience counted against, not for.

Sources

• Order, Document 179, No. CV-23-02090-PHX-DWL (D. Ariz. 24 August 2026), five pages, read in full.
• Located through Damien Charlotin’s AI Hallucination Cases database, which is a compilation and not a primary source.
• Counsel is named because the court imposed a public reprimand and required her to report it. The judge is not named here: the signature block in the copy we read is an image.

Related

• The full sanctions record
• People v. Crabill, the first suspension on this record
• Benjamin v. State, decided the following day, where a referral was expressly declined
• Shelbert v. Baxter, the same week, and the bottom rung

Checked 30 August 2026 against the order text, read in full. Information, not legal advice.