By Tyler Palmer

This article discusses a California Court of Appeal decision confirming the importance of the attorney’s role in ensuring the accuracy of research generated by AI and not delegating the task to non-attorneys.

In Del Biaggio v. Bansen (Cal. Ct. App., 1st Dist., Div. 4, July 10, 2026), the California Court of Appeal confronted what is fast becoming a recurring problem in American courtrooms: an appellate brief containing fictitious case citations generated by artificial intelligence.

The court’s opinion offers further guidance from a California appellate court on exactly what “human verification” of AI-generated legal research requires — and makes plain that delegating that task to a paralegal does not suffice.

The practical lessons of Del Biaggio are clear. Attorneys who use generative AI for legal research must personally read every case they cite and confirm that each quotation is accurate and that the authority actually stands for the proposition asserted. Delegating that verification to non-attorneys — no matter how capable — does not discharge the attorney’s ethical obligation.

Read the full article below and on the Westlaw website here.