Lawyer in AI Misuse Case Fined for Not Supervising Subordinate

A California attorney failed in his professional responsibility to sufficiently supervise another lawyer at his firm who submitted court filings that contained AI-fabricated citations, a federal judge ruled.

Lenden Webb, who practices in Fresno, Cali., is the latest in a fast-growing string of lawyers to be fined over misusing AI through court filings with fabricated citations. But the case appears to be rare because Magistrate Judge Peter H. Kang of the US District Court for the Northern District of California sanctioned Webb primarily for failing to oversee another lawyer at his firm for committing the underlying infraction.

On Tuesday Kang ordered Webb to pay $1,001 as a personal sanction, and to circulate the order to all attorneys and paralegals in Webb’s firm. Webb also must complete four hours of continuing legal education from the State Bar of California, including two hours on supervision of junior attorneys/staff, and at least another two in the area of “ethical/professional use” of AI in legal practice, according to the order.

“Managers in law firms have an obligation to take reasonable steps to ensure all lawyers in the firm make ethical representations to the Court,” the judge said. “Supervisors who do not draft or sign submissions to the court, but who remain counsel of record and fail to question the accuracy of defective pleadings, fail in their duty of supervision.”

In the underlying case, Anthony Hill, Workday Inc.'s former in-house counsel, sued Workday over claims the company discriminated against him because he’s Black and suffers from various disabilities. Webb and Katherine Cervantes misused AI while formerly representing Hill in the case, according to Kang.

In September 2025, Kang admonished Cervantes for her lack of diligence in ensuring the accuracy of the citation submitted to the court.

Neither Webb nor Cervantes disputed that they submitted a brief which included a fake citation to nonexistent law, “caused in part by use of AI and ultimately from a lack of care and lack of supervision,” Kang said.

Webb admitted to Kang that he had “ultimate responsibility as counsel of record,” however the judge added that Webb has taken several steps to make sure the errors don’t happen again. Remedial steps included attending a legal operations convention “‘to work on improving our firm’s efforts to serve clients,’” which included Webb and Cervantes attending “multiple seminars” on AI issues, the order said.

Webb didn’t immediately respond to a request for comment.

Webb Law Group APC represents Webb.

The case is Hill v. Workday Inc., N.D. Cal., No. 3:23-cv-06558, order 4/28/26.