Three attorneys are facing discipline from the State Bar of California after they allegedly cited legal decisions that were not included in court documents submitted that were written using artificial intelligence.
The State Bar of California recently filed notices of disciplinary charges against Omid Emile Khalifeh, an attorney based in Los Angeles, and Steven Thomas Romeyn, an attorney based in Scottsdale, Ariz., accusing them of abusing AI. The Court of Attorneys of the State has not issued a decision on these allegations.
The Federal Circuit Court this month also approved a set of disciplinary measures against Sepideh Ardestani, a Beverly Hills attorney, who was punished for submitting missing and erroneous citations in a March 2025 federal court filing.
Khalifeh, Ardestani and Romeyn could not be reached for comment.
In California, lawyers are allowed to use artificial intelligence tools to draft legal documents. However, they are responsible for verifying all information included in their books.
Senior lawyer George Cardona said that these three cases show how justice is undermined when lawyers fail to ensure the authenticity of their presentations in court. AI tools are known for manipulating, or manipulating information.
“Courts and clients must be able to trust that the attorneys applying are accurate, supported, and up to professional standards,” he said in a statement Monday. “Technology can help to do legal work, but it does not replace the lawyer’s work of skill, diligence and honesty.”
The State Bar filed six misdemeanor charges against Khalifeh related to the alleged misuse of AI in a trademark case filed in federal court in Los Angeles.
Khalifeh is accused of submitting one part of the case that did not exist and two quotes that did not match the arguments they were quoted in the document of April 2025. He is also accused of violating the court order, since 28 Jan. 2025, which requires lawyers to disclose any use of generative AI when submitting applications.
When the court flagged this concern, Khalifeh responded that he had used AI, but insisted that all quotes included in the brief were from actual judicial decisions.
“After being drafted, I revised, updated, and added all parts of the brief, including those informed by the use of Lexis+ AI or based on previous templates,” he wrote in May 2025. “I independently verified the veracity and legal accuracy of the content and ensured that all arguments and authorities were relevant to the issues presented.”
The court responded by again raising concerns that one citation did not exist and the other two AI-assisted citations had “strong” relevance to the case at hand. Khalifeh then admitted that he could not confirm the existence of a single quote and withdrew it from the file.
Romeyn is accused of submitting irrelevant and missing citations to an October 2025 filing of a personal injury lawsuit in Orange County Superior Court.
When the court flagged the complaints, Romeyn disclosed using AI and admitted to reviewing and verifying a few quotes but not verifying all quotes before filing.
The State Bar Court will rule on whether Romeyn and Khalifeh committed professional misconduct and may recommend that their licenses to practice law be suspended or the lawyers be barred. The California Supreme Court decides whether to enforce the recommended discipline.
Ardestani, a Beverly Hills attorney, admitted he was not forthcoming about his use of missing and erroneous citations in a wage-and-hour class action filing filed in federal court in Sacramento in March 2025.
He denied using AI but said the incorrect quotes were the result of his handwritten notes from another issue. He did not provide any documents to support these explanations, according to the Federal Court.
The Eastern District of California said the time it spent reviewing allegations of misconduct was “a waste of limited time and judicial resources in a district that has labored under long-standing hardship.”
The disciplinary terms approved by the State Bar Court on April 6 call for a year of probation and conditions that include a 30-day suspension of Ardestani’s license. He must also complete ten hours of technology-focused continuing legal education, including at least five hours focused on the benefits and risks of AI tools in the legal profession.
