Matter of Sethi, 30 I&N Dec. 112 (BIA 2026)

The same conduct, a second tribunal, a second suspension. Matter of Sethi is the Board of Immigration Appeals' first precedent decision on attorney discipline for AI hallucinations, and it establishes the multiplier that now applies across the tracker: discipline is reciprocal. A sanction in the court where the brief was filed follows the lawyer into every forum that takes the first tribunal's findings.

The Board reviewed the same Ninth Circuit matter: briefs containing citations to cases that do not exist, citations drafted by the firm's unlicensed brief writers and filed without verification, a Motion to Correct that falsely characterized the hallucinated citations as "typographical errors," and knowingly false statements to the court about AI use. The Board adopted the Ninth Circuit's findings under reciprocal-discipline doctrine.

Reciprocal discipline, on the obligations of candor and verification that apply regardless of the drafting tool. Sethi was suspended from practice before the Board of Immigration Appeals, the Immigration Courts, and the Department of Homeland Security for six months, retroactive to June 13, 2026. The Board rejected the argument that discipline for AI-related conduct is unprecedented or an outlier penalty.

One tribunal's sanction now follows you across the whole system, so a single AI-hallucination matter can cost practice before multiple bars and agencies at once. Verify every citation your staff or brief writers draft before it is filed, and never call a fabricated case a typo. After this decision, arguing that AI discipline is unprecedented fails as a matter of published precedent.

This case is covered in Episode 14: Name the Source (watch on YouTube).

• Reporting: https://www.novo-legal.com/en/blog/bia-matter-sethi-ai-hallucinations-attorney-discipline
• gceb1.com: https://gceb1.com/why-using-ai-to-build-an-immigration-case-can-backfire