The Brief

A Los Angeles-area attorney must pay a $10,000 fine for filing a state court appeal full of fake quotations generated by the artificial intelligence tool ChatGPT.

The fine appears to be the largest issued over AI fabrications by a California court and came with a blistering opinion stating that 21 of 23 quotes from cases cited in the attorney’s opening brief were made up. It also noted that numerous out-of-state and federal courts have confronted attorneys for citing fake legal authority.

“We therefore publish this opinion as a warning,” it continued. “Simply stated, no brief, pleading, motion, or any other paper filed in any court should contain any citations— whether provided by generative AI or any other source—that the attorney responsible for submitting the pleading has not personally read and verified.”

The opinion, issued 10 days ago in California’s 2nd District Court of Appeal, is a clear example of why the state’s legal authorities are scrambling to regulate the use of AI in the judiciary. The state’s Judicial Council two weeks ago issued guidelines requiring judges and court staff to either ban generative AI or adopt a generative AI use policy by Dec. 15. Meanwhile, the California Bar Association is considering whether to strengthen its code of conduct to account for various forms of AI following a request by the California Supreme Court last month.

The attorney fined last week, Amir Mostafavi, told the court that he did not read text generated by the AI model before submitting the appeal in July 2023, months after OpenAI marketed ChatGPT as capable of passing the bar exam. A three-judge panel fined him for filing a frivolous appeal, violating court rules, citing fake cases, and wasting the court’s time and the taxpayers money, according to the opinion.

Mostafavi told CalMatters he wrote the appeal and then used ChatGPT to try and improve it. He said that he didn’t know it would add case citations or make things up.

He thinks it is unrealistic to expect lawyers to stop using AI. It’s become an important tool just as online databases largely replaced law libraries and, until AI systems stop hallucinating fake information, he suggests lawyers who use AI to proceed with caution.

“In the meantime we’re going to have some victims, we’re going to have some damages, we’re going to have some wreckages,” he said. “I hope this example will help others not fall into the hole. I’m paying the price.”

The fine issued to Mostafavi is the most costly penalty issued to an attorney by a California state court and one of the highest fines ever issued over attorney use of AI, according to Damien Charlotin, who teaches a class on AI and the law at a business school in Paris. He tracks instances of attorneys citing fake cases, primarily in Australia, Canada, the United States, and the United Kingdom.

In a widely-publicized case in May, a U.S. district court judge in California ordered two law firms to pay $31,100 in fees to defense counsel and the court for costs associated with using “bogus AI-generated research.” In that ruling, the judge described feeling misled, said they almost cited fake material in a judicial order and said “Strong deterrence is needed to make sure that attorneys don’t succumb to this easy shortcut.”

Charlotin thinks courts and the public should expect to see an exponential rise in these cases in the future. When he started tracking court filings involving AI and fake cases earlier this year, he encountered a few cases a month. Now he sees a few cases a day. Large language models confidently state falsehoods as facts, particularly when there are no supporting facts.

“The harder your legal argument is to make, the more the model will tend to hallucinate, because they will try to please you,” he said. “That’s where the confirmation bias kicks in.”

A May 2024 analysis by Stanford University’s RegLab found that although three out of four lawyers plan to use generative AI in their practice, some forms of AI generate hallucinations in one out of three queries. Detecting fake material cited in legal filings could get harder as models grow in size.

Another tracker of cases where lawyers cite nonexistent legal authority due to use of AI identifies 52 such cases in California and more than 600 nationwide. That amount is expected to increase in the near future because AI innovation is outpacing the education of attorneys, said Nicholas Sanctis, a law student at Capital University Law School in Ohio.

Jenny Wondracek, who leads the tracker project, said she expects this trend to get worse because she still regularly encounters lawyers who don’t know that AI makes things up or believe that legal tech tools can eliminate all fake or false material generated by language models.

“I think we’d see a reduction if (lawyers) just understood the basics of the technology,” she said.

Like Charlotin, she suspects there are more instances of made up cases generated by AI in state court filings than in federal courts, but a lack of standard filing methods makes it difficult to verify that. She said she encounters fake cases most often among overburdened attorneys or people who choose to represent themselves in family court.

She suspects the number of arguments filed by attorneys that use AI and cite fake cases will continue to go up, but added that not just attorneys engage in the practice. In recent weeks, she’s documented three instances of judges citing fake legal authority in their decisions.

As California considers how to treat generative AI and fake case citations, Wondracek said they can consider approaches taken by other states, such as temporary suspensions, requiring attorneys who get caught to take courses to better understand how to ethically use AI, or requiring them to teach law students how they can avoid making the same mistake.

Mark McKenna, codirector of the UCLA Institute of Technology, Law & Policy praised fines like the one against Mostafavi as punishing lawyers for “an abdication of your responsibility as a party representing someone.” He thinks the problem “will get worse before it gets better,” because there’s been a rush among law schools and private firms to adopt AI without thinking through the appropriate way to use them.

UCLA School of Law professor Andrew Selbst agrees, pointing out that clerks that work for judges are recent law school graduates, and students are getting bombarded with the message that they must use AI or get left behind. Educators and other professionals report feeling similar pressures.

“This is getting shoved down all our throats,” he said. “It’s being pushed in firms and schools and a lot of places and we have not yet grappled with the consequences of that.”

According to the Recording Academy itself, the Grammy for best new artist is for musicians who are having "a breakthrough into the public consciousness."

What did it look like to have a breakthrough moment in 2025? More often than not, it meant having a hit song on TikTok. At this weekend's Grammys, all eight best new artist nominees are musicians whose popularity skyrocketed thanks to the app.

"If there's anything that speaks to TikTok's power right now, I think it's this category in particular," says Robert Steiner, a media analyst at the music and entertainment insights company Luminate.

Last year, Luminate partnered with TikTok on a Music Impact report. It found what many powerbrokers in the music industry have known for awhile: The app is not only a large source of music discovery, but also a leading driver of chart success. According to the report, 84% of songs that entered Billboard's Global 200 chart went viral on TikTok first.

And music, in turn, is essential to the app as well. Steiner says going all the way back to its roots in Musically — a platform for lip-syncing videos — songs have been the currency for TikTok's biggest memes and dances.

"A lot of the trends that we see on TikTok are audio-based. Obviously video is part of it, but the sound is a huge aspect of it as well," Steiner says. "It was set up to really capitalize on audio becoming a key driver to the app, and I think as a result, it does seem like they created at least a segment of their user base that is very musically inclined."

Looking at this year's Grammy nominations, the best new artist contenders run the gamut from indie darlings who started making music a decade ago to former Hype House TikTok creators who launched recording careers in 2025. All eight nominees used the app in their ascent to pop stardom — but did they rise through the music industry into TikTok virality? Or the other way around?

Olivia Dean

The English singer is not a newcomer; as she told NPR's Morning Edition in September, she's been recording and releasing music for nearly a decade. In 2023, her album Messy was shortlisted for the U.K.'s Mercury Prize. But in 2025, the warm soul-pop melodies of her album The Art of Loving put her on the map in a major way. The single "Man I Need" became a hit on TikTok — it's been used in 1.7 million videos so far, according to the app — and quickly climbed the charts.

Did Olivia Dean come from TikTok or the music industry: The music industry. 

KATSEYE

Born out of a reality television competition show in 2023, KATSEYE is a global girl group seemingly created for TikTok virality — and so far, the sextet has delivered. In 2025, singles like "Gnarly" and "Gabriela" steadily climbed the charts; but perhaps more importantly, they soundtracked millions of videos on TikTok. Choreography from KATSEYE's Gap commercial (set to "Milkshake" by Kelis, not their own song) became a dance trend too, heralded as a clap back to Sydney Sweeney's controversial American Eagle jeans ad. In December, TikTok officially crowned KATSEYE its Global Artist of 2025.

Did KATSEYE come from TikTok or the music industry? Both.

The Marías

The indie pop band started releasing synth-driven, bilingual songs nearly a decade ago and collaborated with Bad Bunny on his 2022 album Un Verano Sin Ti. But it was a demo of their song "No One Noticed," which lead singer María Zardoya released unofficially on her TikTok account, that would become the band's biggest song to date, and was later officially released on their 2024 album Submarine. Zardoya told podcast host Zach Sang that despite being a slower, introspective song — the opposite of what the band's label wanted at the time — fans gravitated towards it on social media.

Did The Marías come from TikTok or the music industry? The industry via the independent route — they built a fanbase and eventually landed a record deal with Atlantic, then hit big on the app. 

Addison Rae

Originally from Lafayette, La. — cue the Britney Spears comparisons — Addison Rae became a TikTok sensation in 2019 by posting videos of herself dancing to viral songs. She moved to Los Angeles, joined the Hype House and amassed millions of followers, all of which then helped build momentum for a music career. After a co-sign from Charli XCX on the "Von Dutch" remix, she released her effervescent debut album Addison in June.

Did Addison Rae come from TikTok or the music industry? TikTok. 

sombr

Hailing from New York City's Lower East Side, the Gen Z rocker sombr has had his share of viral TikTok songs. His 2022 single "Caroline" was the first, helping him get signed to Warner Records when he was still 17 years old. Two more followed in 2025; his singles "Back to Friends" and "Undressed" were used on hundreds of thousands of TikTok videos and both steadily climbed Billboard's Hot 100 chart, months before sombr released his debut album I Barely Know Her.

Did sombr come from TikTok or the music industry? Both. 

Leon Thomas

A child Broadway star and former Nickelodeon actor, it's safe to say Leon Thomas has been grinding for decades. After being mentored by Babyface for years, the 32-year-old has produced for artists ranging from his Victorious co-star Ariana Grande to Rick Ross. In 2024, he won a Grammy for best R&B song for his contributions to SZA's "Snooze." But Thomas' sophomore album, MUTT, landed him directly in the spotlight — its lead single took off on TikTok and climbed Billboard's Hot 100 chart. Of this year's best new artist contenders, Thomas is the most widely recognized by the Recording Academy; he landed five additional nominations, including for album of the year.

Did Leon Thomas come from TikTok or the music industry? The music industry. 

Alex Warren

Another member of the Hype House collective, Alex Warren went from posting massively popular pranking videos online to releasing a romantic ballad — and instant wedding playlist staple — that spent months climbing Billboard's Hot 100 chart. "Ordinary" became one of the biggest hits of the summer, and earned Warren an invitation to perform with country superstar Luke Combs at Lollapalooza.

Did Alex Warren come from TikTok or the music industry? TikTok.

Lola Young 

Often drawing comparisons to previous best new artist winner Amy Winehouse, the 25-year-old had already released several albums before her 2024 single "Messy" went viral on TikTok. Young's songs had already been gaining traction on the app for a while — videos of her performing "Don't Hate Me" on a playground in 2023 racked up millions of views — but "Messy" became a different kind of phenomenon. Before performing at Coachella last spring, Young told NPR's Morning Edition that she does not identify as a TikToker, but recognized the massive impact the app has had on her career.

Did Lola Young come from TikTok or the music industry? The music industry.

More than a century after it first opened its doors, the Vermont Square Branch of the Los Angeles Public Library still is operating out of its original building, nestled among the homes on West 48th Street.

It’s not just a library. For generations, it’s been considered a safe place and gathering spot for people who otherwise may have no place to go. Today, the neighborhood council uses the room in the library’s basement for meetings, the grassy area out back is a place to relax, and for some, the building is a refuge from hot- and cold-weather days.

Of course, people also go there to read books, for free access to the internet and for children’s programming. But they also go there to find peace and quiet amid the hustle and bustle of inner-city Los Angeles.

“It feels safe. It’s pretty big. It’s nice inside and comfortable. There are people to talk to, and I can meet friends,” resident Moses Rogers told The LA Local.

The Vermont Square Branch was built in 1913 on what had been park land donated by the city of Los Angeles. It was funded with a Carnegie Foundation grant, the philanthropy of industrialist Andrew Carnegie, who funded the arts, higher education and public libraries after making his fortune in steel in the late 19th century.

The library is not the oldest branch in the city system, but it’s the first library building owned by the city. All other city libraries and facilities were housed in rented spaces.

It was designed in the architectural style of the Italian Renaissance, and you still can find the original circulation desk, windows that allow in natural light, old furniture and marble fixtures inside the library.

Branch manager Martha Sherod has worked at the library for 13 ½ years and calls the Vermont Square Branch a hidden treasure that some in the neighborhood can overlook. She said some people think it’s a government building, but for the people who grew up using the library, it symbolizes being home.

“People come here for a purpose, they want to be here. We really like serving them,” Sherod told The LA Local. “Now that I’ve been here so long, I’ve seen kids grow up from being little kids to college students. So, it’s really been a joy for me.”

Sherod said the branch holds about 24,000 items and has 4,500 visitors a month on average. The library also offers adult and teen programming, including free legal advice, health screenings, arts and crafts and book club activities.

“The library isn’t just for quietly sitting and reading. There’s usually a lot of good activities happening. There are resources that you can use at home by downloading or just coming in here,” Sherod said.

The Vermont Square Branch was designated by the Los Angeles Cultural Heritage Commission in 1983 after the community rallied to keep the building from being replaced. The exterior of the building remains the same, although the library was retrofitted for earthquake safety in 1990, a process that caused the branch to close to the public for six years.

Longtime Vermont Square resident Fletcher Fair told The LA Local she’s been going to the branch since the late 1960s, and the library will always be a cornerstone of the community.

“It’s the neighborhood library, and that’s where everyone went and prospered. We hung out, studied and partied,” she said. “There were a lot of events here.”

The first measles case of the year in Los Angeles County has been confirmed by the L.A. County Department of Public Health.

County public health officials said Friday a county resident who recently traveled abroad has been confirmed to have measles. Authorities have not identified any locations, other than healthcare settings, where the person could have exposed others.

Affected healthcare facilities are contacting patients and employees about potential exposure. County officials also are in the process of identifying those who may have had contact with the person.

Measles spreads easily through the air and can stay on surfaces for many hours. Those infected can spread the virus before showing symptoms, which can take weeks to appear.

Symptoms include a fever above 101 degrees; cough; runny nose; red, watery eye; and a rash that typically starts on the face.

So far, 588 measles cases of measles have been reported in the U.S. this year, the highest number of cases in a January since the U.S. eliminated measles in 2000. Most of these cases are linked to outbreaks in South Carolina, Arizona and Utah.

The L.A. County Department of Public Health is encouraging Angelenos to check their immunization statuses for a measles, mumps, rubella vaccine to determine if they’re protected against the virus.

Residents also should notify their health providers for guidance in the case of a potential exposure.

If symptoms develop, contact a healthcare provider via phone as soon as possible. L.A. Public Health advises people not to go physically into a health care facility before notifying them of measles symptoms.

The leaders of the Los Angeles Unified teachers union now have the power to call for a strike if they can’t reach a deal over pay, benefits and student support with the district.

United Teachers Los Angeles’ has about 37,000 members. Of those who voted, 94% voted in favor of authorizing a strike. The tabulation process lasted late Friday night, and results were announced overnight Saturday.

Union members, which include school psychologists, counselors and nurses, simultaneously voted to approve an agreement that preserves existing health benefits without increasing costs to educators.

The strike authorization vote does not guarantee teachers will stage a walkout this semester. First, the union must exhaust all steps of the collective bargaining process.

Stephanie Castro teaches seventh-grade English at Luther Burbank Middle School in Highland Park and voted for the strike authorization.

“ I will do what needs to be done to fight for these proposals,” Castro said. “I want to make it super clear to Angelenos that teachers don't want to go on strike. We absolutely would rather be in our classrooms with our students. … We also know that things cannot continue as they are.”

In a statement Saturday, the district pointed to other recent agreements with its labor unions, while also citing fiscal challenges related to declining enrollment and other factors: "We recognize the real financial strain on educators and staff but must make difficult decisions to preserve classrooms, student services and long-term stability within finite resources."

How did we get here? And what happens next?

UTLA’s bargaining team has met with the district more than a dozen times since negotiations began last February.

The union declared an impasse in December, a legal step that triggers intervention from a neutral mediator appointed by the state’s labor relations board.

On Wednesday, the mediator determined the two parties would move to the next step in the process, fact-finding, wherein a representative from the union, the district and the California Public Employment Relations Board collectively develop a recommendation to settle the negotiations.

The rejection of this panel’s recommendation could lead to a strike — or more negotiating.

As in previous contract talks, the proposals that cost the most money are those that take the longest to hash out.

The union is asking for raises and changes to the salary schedule so that newer teachers who complete professional development can earn increases more quickly. UTLA estimated before mediation that this would amount to an average pay increase of 16% the first year and 3% the following year. The annual ongoing cost to the district would be about $840 million.

The district has said it cannot afford what the union has proposed and has offered annual increases of 2.5% the first year and 2% the second year with a one-time payment of 1%.

“Significant distance remains between what the district can responsibly offer and what UTLA proposes,” read a Jan. 28 statement from LAUSD.

The union’s other proposals include more investment in arts education, legal aid for immigrant families and staff to support students’ mental health.

Castro, the middle school teacher, said she notices a difference when her students have access to the school’s psychiatric social worker and other wraparound services.

“It allows them to be fully present in the classroom,” Castro said. “They're not so worried about things that are happening outside of it and can really focus on that essay that they need to write or developing a thesis statement.”

Are you a UTLA member? Share your thoughts on your strike authorization vote with me via email.