Three attorneys are facing disciplinary action from the California State Bar after allegations that they cited nonexistent legal decisions in court filings that were written using artificial intelligence.
The California Bar recently filed notices of disciplinary charges against Omid Emile Khalifeh, a Los Angeles-based attorney, and Steven Thomas Romeyn, a Scottsdale, Arizona-based attorney, accusing them of misusing AI. The State Bar Court has not ruled on the allegations.
The State Bar Court this month also approved a series of disciplinary actions against Sepideh Ardestani, a Beverly Hills attorney, who was disciplined for filing nonexistent and erroneous subpoenas in a March 2025 federal court filing.
Khalifeh, Ardestani and Romeyn could not immediately be reached for comment.
In California, lawyers can use generative artificial intelligence tools to draft legal documents. However, they are responsible for verifying all information included in their submissions.
Lead trial attorney George Cardona said the three cases demonstrate how justice is undermined when attorneys do not confirm the accuracy of their submissions to the court. AI tools are known to hallucinate or fabricate information.
“Courts and clients must be able to trust that the submissions lawyers make are accurate, supported and meet professional standards,” he said in a statement Monday. “Technology can assist legal practice, but it does not replace a lawyer's duty of competence, diligence and honesty.”
The State Bar has filed six counts of misconduct against Khalifeh related to his alleged misuse of AI in a trademark case filed in federal court in Los Angeles.
Khalifeh is accused of submitting a citation from a case that did not exist and two citations that were not relevant to the arguments for which they were cited in a document from April 2025. He is also accused of violating the court's standing order, effective Jan. 28, 2025, requiring lawyers to disclose any use of generative AI when filing filings.
When the court pointed out these concerns, Khalifeh responded by saying that he had used AI, but insisted that all quotes included in the brief came from actual court decisions.
“After drafting, I reviewed, revised, and supplemented all parts of the brief, including those that relied on the use of Lexis+ AI or previous templates,” he wrote in May 2025. “I independently verified the factual and legal accuracy of the content and confirmed that all arguments and authorities were appropriate to the issues presented.”
The court responded by once again raising concerns that one subpoena was non-existent and two other AI-assisted subpoenas had only “weak” relevance to the case at hand. Khalifeh later admitted that he could not verify the existence of a quote and removed it from the presentation.
Romeyn is accused of filing irrelevant and non-existent subpoenas in an October 2025 filing for a personal injury case in Orange County Superior Court.
Once the court noted his concerns, Romeyn revealed that he had used AI and admitted that he had reviewed and verified several of the subpoenas, but did not verify each and every subpoena before submitting them.
The State Bar Court will rule on whether Romeyn and Khalifeh committed professional misconduct and could recommend that their licenses to practice law be suspended or that the attorneys be disbarred. The California Supreme Court determines whether to impose recommended discipline.
Ardestani, the Beverly Hills attorney, admitted that she was not forthcoming about the use of nonexistent and erroneous subpoenas in filings for a wage and hour class action lawsuit filed in federal court in Sacramento in March 2025.
He did not admit to using AI, but claimed that the incorrect quotes were due to his handwritten notes on another matter. According to the State Bar Court, he did not provide any documents to support these explanations.
The Eastern District of California said the time it spent reviewing his alleged misconduct was a “waste of limited judicial time and resources in a district that has labored under a long-running case crisis.”
The disciplinary stipulation approved by the State Bar Court on April 6 calls for a one-year probationary period with conditions including a 30-day suspension of Ardestani's license. You must also complete ten hours of technology-focused continuing legal education, including at least five hours focused on the benefits and risks of artificial intelligence tools in legal work.
