Fadi El Bitar v. Julio Hernandez, et al.
The case
Fadi El Bitar v. Julio Hernandez, et al., W.D. Wash., Case No. 2:26-cv-00919-TMC, sanctions order filed June 2, 2026 (Judge Tiffany M. Cartwright). Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-154-el-bitar-v-hernandez.pdf`.
What happened
Legal interns working for drafting attorney Julian Mansoor Daman used Google Gemini to generate text for a habeas petition and traverse; Gemini fabricated quotes and confidently presented them as binding Ninth Circuit precedent. Daman filed the briefs without independent verification and accepted full responsibility.
The rule and the sanction
Rule 11, Federal Rules of Civil Procedure. Sanctions: Daman personally sanctioned $1,000 (payable to the court clerk within 21 days) plus a public reprimand. Local counsel Jennifer Nimer was also reprimanded for rubber-stamping the filings but was not fined.
How it could have been avoided
Supervising attorneys must personally verify intern research, especially AI-generated material. Local counsel should not sign on as a formality; the non-delegable duty attaches to every signer.
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