Case D-86 · AI Sanctions Case Tracker

Fang v. Hechalou US LLC

U.S. District Court for the Central District of California, September 12, 2025

The case

Yi-Sheng Fang, et al. v. Hechalou US LLC, et al., No. CV 25-1180 PA (JDEx), C.D. Cal., order filed September 12, 2025 (Judge Percy Anderson). Copy of primary document: `files/sources/D-86-fang-v-hechalou.pdf`.

What happened

Attorney Daniel H. Ngai of Luther & Lanard, PC admitted that his firm used AI to generate the citations in a brief and then failed to verify them, filing inaccurate and fictitious authorities with the court.

The rule and the sanction

The court found reckless conduct under 28 U.S.C. section 1927. Luther & Lanard, PC was ordered to pay $2,418.50 to opposing counsel, to notify the State Bar of California, and to file a compliance declaration with the court.

How it could have been avoided

Never delegate citation checking to an AI tool alone; a human attorney must open and read each cited case. Build a firm-wide rule that every brief's authorities are verified against the original source before filing. When an AI-assisted draft contains new authorities, re-run them through a conventional legal database check.