The sanctions record · U.S. Court of Appeals, Ninth Circuit
Sethi and Rounds, and the two-year disclosure order
LNU v. Blanche, 177 F.4th 1014 (9th Cir. 2026) · U.S. Court of Appeals for the Ninth Circuit · followed by Matter of Sethi, 30 I&N Dec. 112 (BIA 2026)
Ninth Circuit sanctions order: not read at source. The account of it below is recorded from contemporaneous reporting and official statements, not quoted from the order. Board of Immigration Appeals decision: read in full; every quotation in that section is from it.
The remedy no other court on this record has imposed. Not just money, and not just a suspension: the firm must disclose generative AI use in its filings for two years. A court turned a sanction into a compliance programme with an end date.
What happened
- The caseLNU v. Blanche, an immigration matter. The attorneys were Orange County practitioners Mike Singh Sethi and William Rounds.
- The defectsBriefs containing non-existent cases, invented quotations, and grossly inaccurate descriptions of real law. All three failure modes in one filing.
- Money$2,500 each.
- SuspensionBoth suspended from practice before the Ninth Circuit for six months.
- The firmOrdered to disclose generative AI use in future filings for two years.
As reported, the court had ruled in the clients’ favour, halting the deportation of three family members. The sanctions followed anyway.
The Board of Immigration Appeals follows: Matter of Sethi
The suspension then travelled. In Matter of Sethi, 30 I&N Dec. 112 (BIA 2026), the Board of Immigration Appeals imposed reciprocal discipline on Mike Singh Sethi. The decision concerns Sethi only; Rounds is not named in it. It was first issued unpublished on 15 September 2026 and designated as a precedent decision on 1 October 2026.
“The Board hereby suspends the respondent from practice before the Board of Immigration Appeals, the Immigration Courts, and DHS for 6 months, effective June 13, 2026.”
The Board records that the Ninth Circuit’s decision issued on 3 June 2026 and suspended Sethi from practice in that court for six months, effective 13 June 2026; the Board’s suspension runs from the same date. It describes what the Ninth Circuit disciplined him for: “citing cases that did not exist, attributing quotations to opinions in which the quoted language did not appear, misrepresenting the content of real legal authority, failing to identify existing law he claimed supported his arguments, knowingly making false statements of law to the court, and failing to correct false statements of law previously made to the tribunal.”
Sethi argued that discipline for misconduct related to AI was an “outlier penalty”. The Board disagreed:
“an attorney must conduct himself or herself in accordance with governing rules of professional conduct regardless of the tools he or she uses to prepare and present cases.”
He also pointed to what the record lacked, including draft history or metadata tracing the brief’s language to AI, and a prompt or response. The Board held that he had not shown the infirmity of proof the regulations require, because, as the Ninth Circuit explained, his actual knowledge of the AI use could be inferred from the circumstances.
Why the disclosure order is the important part
Every AI standing order on the orders page applies prospectively to everyone appearing before that judge. This is different. It is a remedial obligation, imposed on one firm, after the fact, running for two years, and it attaches to the firm rather than to the two individuals who filed the briefs.
Compare the parallel remedies elsewhere. British Columbia, in Zhang v. Chen, ordered counsel to review every other file before the court and report within thirty days, which looks backwards. The Ninth Circuit looks forwards. Between them they define the range of what a court will now order beyond a payment.
What it changes
It is the first American order that makes AI disclosure an ongoing operational obligation with a compliance burden attached, and it lands on a firm rather than a person. A firm under it has to know, for every filing across every matter for two years, whether generative AI touched the document and be able to say so. That is not a policy question. It is a records system, imposed by a court.
It is also the sharpest illustration that winning does not help. The clients prevailed. The lawyers were suspended.
What to do about it
A two-year, firm-wide duty to disclose AI use in every filing cannot be carried in anyone’s head across hundreds of matters. What the court described is a records system. A signed record of which AI you used and what a person checked, sealed to the exact file you deliver, made on your own machine and checkable free by anyone you send it to.
For a firm rather than a practitioner, the same engine runs across the estate: Regulayer™ for enterprise. See also the attorney certification and every jurisdiction we track.
Sources
- Ninth Circuit sanctions order in LNU v. Blanche, 177 F.4th 1014 (9th Cir. 2026), the reporter citation as the Board of Immigration Appeals gives it. Not read at source.
- Matter of Sethi, 30 I&N Dec. 112 (BIA 2026), Interim Decision #4254, decided 1 October 2026, nine pages, read in full at the Executive Office for Immigration Review’s own site. It cites the Ninth Circuit decision as Malkeet Lnu v. Blanche, 177 F.4th 1014 (9th Cir. 2026).
- Supreme Court of the United States, docket No. 26-296, read at the Court’s own site
- Recorded from contemporaneous reporting, including Bloomberg Law and the Metropolitan News-Enterprise. This page carries no quotation from the order.
Related
- The full sanctions record
- Every verified AI standing order
- Zhang v. Chen, the backward-looking equivalent
- Nebraska, the other US suspension
The Ninth Circuit order was not read at source. Treat the detail of it as reported until it is pulled. The Board’s decision was read in full.
Common questions
What did the Ninth Circuit do in the Sethi and Rounds matter?
It sanctioned two Orange County immigration attorneys whose briefs contained non-existent cases, invented quotations and grossly inaccurate descriptions of real law. Each was fined $2,500. Both were suspended from practice before the Ninth Circuit for six months. Their firm was ordered to disclose generative AI use in future filings for two years.
Is a court-ordered AI disclosure obligation unusual?
A two-year, firm-wide, prospective one is. Standing orders requiring disclosure apply to everyone in a judge's court from the outset. This was imposed as a remedy on one firm after the fact, which makes it the closest this record comes to a court-supervised compliance regime.
Did the clients suffer?
Not in the outcome. As reported, the court had ruled in favour of the attorneys' clients, halting the deportation of three family members. The sanctions were imposed notwithstanding that the clients had won, which underlines that the duty runs to the court rather than to the result.
Which US courts have suspended lawyers over AI citations?
On this record, the Ninth Circuit suspended two attorneys from practice before that court for six months, and the Nebraska Supreme Court suspended an Omaha attorney from the practice of law until further notice in April 2026. The Board of Immigration Appeals then suspended Sethi from practice before the Board, the Immigration Courts and DHS for six months, effective 13 June 2026, as reciprocal discipline.
Sethi has petitioned the Supreme Court of the United States for a writ of certiorari, Sethi v. United States Court of Appeals for the Ninth Circuit, No. 26-296: petition filed 1 September 2026, docketed 8 September 2026. The federal respondents waived their right to respond, and the petition is distributed for the Court’s conference of 6 November 2026.
Information, not legal advice, and not advice on the law of any jurisdiction. Every entry is verified against the issuing body’s own document; where a source is reporting rather than the document, we say so.