Matter of Sethi: An Immigration Lawyer Suspended for a Brief Citing Cases That Did Not Exist and Quotes That Were Never Written

This is an attorney-discipline decision, not a case about a client. It became precedent because the Board wants every lawyer who appears before it to read it. Clients should read it too.

What happened

The Ninth Circuit suspended the attorney for six months, effective June 13, 2026, after he filed a brief in an immigration appeal containing what the Board calls “artificial intelligence hallucinations” — citations to cases that did not exist and quotations that appeared in no opinion — and then made false statements to the court about his use of artificial intelligence. EOIR’s and DHS’s disciplinary counsel jointly petitioned for reciprocal discipline; the Board imposed an immediate suspension in July and, in this decision, made it final for the same six-month term. The attorney argued the proof was infirm and the result unjust. The Board found no disputed fact requiring a hearing and rejected both arguments under its long-standing reciprocal discipline cases.

Why it is precedent

The Board publishes only a small fraction of its decisions as precedent, and it chose this one. The message is institutional: a fabricated citation is a false statement to a tribunal, the use of software does not change that, and discipline imposed by a federal court will presumptively be mirrored in immigration court — absent clear and convincing proof of a due-process failure, an infirmity of proof or a grave injustice, there is no second trial of the facts.

What it means for clients

Immigration cases are increasingly decided on paper — as Matter of G-R-B- showed last month, an asylum application can be pretermitted on the written filing alone, without a motion from the government. A brief is not a formality; it is often the whole case. Anyone paying for one is entitled to know that the authorities in it are real and have been read. The questions to ask are simple: who wrote this, what tools were used, and were the cases checked. A lawyer who cannot answer them comfortably is the subject of this decision, not its reader.

For the record: this firm uses research tools, including AI, in the way it uses a law library. Every citation in a filing is verified against the primary source before it goes out, by a person, every time. The Board’s decision describes the standard we think the profession should have been holding all along.

This article is general legal information about a published disciplinary decision, not legal advice, and does not create an attorney-client relationship. The facts stated are drawn from the Board's published decision. This website is attorney advertising.