California's SB 574 Citation Law: An FAQ for Litigators

California just added one sentence to its sanctions statute, and that sentence may change how your team builds a brief.

Starting January 1, 2027, every paper filed in a California court "shall not contain any citations that an attorney responsible for submitting the pleading has not personally verified, including any citation provided by generative artificial intelligence." Note that this sentence says personally verified, not just “verified by someone on the team.”

In my roles at BriefCatch and Norton Law, I’ve been fielding many questions about SB 574. Here are the most frequent questions, my answers, and my recommendations for verifying citations now. 

SB 574 covers every citation, not just AI's 

What is the new California citations law?

The new law is SB 574, signed on September 30, 2026, as Chapter 858. Among other things, it amends Code of Civil Procedure section 128.7 to add the citation-verification sentence. It also adds Business and Professions Code section 6068.1, which bars lawyers from delegating the practice of law to generative AI and requires "reasonable steps to verify the accuracy" of AI output, citations included.

When does SB 574 take effect?

January 1, 2027. No court has interpreted it yet.

Does SB 574 apply only to AI-generated citations?

No. The text covers "any citations," and AI is listed as an example ("including"), not a limit. A case pulled from a partner's memo, an old brief, or a junior associate's research counts just as much as one suggested by a chatbot.

What counts as a "citation" under SB 574?

The statute doesn't say. The safe assumption: every case, statute, rule, and secondary source you cite, plus every quotation and pin cite attached to it. A citation to a real case isn't “verified” if the case doesn't hold what your brief says it does. 

Under SB 574, supervision is not verification 

Can we still split cite-checking across the team?

The statute isn’t clear on that point. Many teams divide and conquer. One associate takes Section I, a paralegal takes Section II, a summer associate takes some string cites. The new language does not prohibit that approach. It does require that citations be“personally verified” by “an attorney responsible for submitting the pleading.”

Until courts clarify what that means, the safest course is to make one attorney responsible for the filing personally review every citation before submission. Others can still pull cases, flag problems, and fix formatting. But the final pass belongs to one attorney. 

Does the attorney who signs the brief have to be the one who verifies?

The statute doesn’t say. The signer is an obvious candidate for “an attorney responsible for submitting” the filing, but the language could also encompass other attorneys. And when several attorneys share responsibility for a filing, must one of them personally verify every citation? The statute doesn't say. Courts will have to decide.

What have California courts said about supervising attorneys and AI hallucinations?

The courts have not yet interpreted section 128.7’s new verification provision, but we recommend a cautious approach to interpreting the phrase “responsible attorney.” Recent orders have held supervising attorneys responsible for AI hallucinations in filings they did not personally draft. 

Two recent sanctions orders point the same way: supervision is not verification:

• In Hill v. Workday (N.D. Cal. Apr. 28, 2026), a discovery motion cited nonexistent case law that came from an AI research tool. The court held that "the duty to check every paper filed in court for accuracy and veracity is nondelegable to other attorneys or to technology" and that authorities "must be checked against the underlying source before submission." The responsible attorney paid a personal sanction and had to take CLE on supervising junior staff.
• In Southland Homes v. Lam (O.C. Super. Ct. App. Div. Aug. 4, 2026), an associate used ChatGPT and Gemini, and the brief included nonexistent cases and mischaracterized real cases. The supervising attorney had reviewed the arguments and the grammar but not the citations. The court sanctioned both lawyers: $2,500 for the supervisor and $1,500 for the associate.

These are just a few representative sanction orders. With this in mind, litigators should be cautious. Until California courts interpret the new language, attorneys responsible for a filing should not assume that someone else’s cite-checking satisfies their own verification obligations.

“Verified” means more than checking if a case exists

Is confirming a case exists enough to verify a citation?

No. Hallucinated cases get the headlines. Harder errors involve real cases. The California Supreme Court recently referred counsel to the State Bar for misquoting and inverting the holdings of real precedents. And in Southland Homes, the problems included a wrong page reference and real decisions cited for points they didn't support.

A citation is verified when you know three things:

1. The authority exists and the cite is right.
2. Every quotation matches the source, word for word, with ellipses where words are missing.
3. The description of the case is accurate and case actually holds what your brief or motion says it holds.

Do KeyCiting and Shepardizing satisfy SB 574's verification requirement?

Only part of it. A citator tells you whether a case is still good law. It doesn't tell you whether the case says what your brief says it says. You need both answers.

What might a conservative verification process for citations look like?

For teams that choose to have one responsible attorney personally review every citation, it  doesn’t have to mean starting the cite-check from scratch. This approach might entail: 

1. Let the team draft and research as usual.
2. Run the full brief through a tool that reads each cited opinion and flags mismatches.
3. The responsible attorney reviews every result, not just the flags, and opens and reviews each linked source.
4. Run a citator for subsequent history.
5. Keep a record of who verified what, and when.

Where BriefCatch fits

Can BriefCatch’s RealityCheck verify citations for me?

No tool can perform your "personal" verification for you, and we wouldn't want you to read the statute that way. What RealityCheck can do is make personal verification realistic for a lawyer facing a deadline.

For every case your team cites, RealityCheck reads the opinion and asks the question a citator doesn't: does this case say what your brief says it does? It checks:

• Quotations. It flags altered quotes, such as a phrase dropped without an ellipsis, and shows you the opinion's actual language.
• Holdings and dispositions. It flags misstated holdings and dispositions, and propositions that stretch a case beyond what it holds.
• Support. It flags citations that don't back the proposition they're attached to.
• Existence. If RealityCheck can't locate a case in any of three case-law sources, it marks the citation "verify by hand" rather than treating it as confirmed.

Each citation RealityCheck checks gets a clear verdict with an explanation, making it easier for an attorney conducting a final verification pass to review the full set and spend more time where it's needed.

How does that map to the suggested workflow process?

• One reviewer, the entire brief. For teams taking the conservative approach of having one attorney review every citation, BriefCatch’s RealityCheck analyzes the brief as a whole, so one reviewer sees every result in one place rather than in pieces.
• Focus on what matters. Verified citations clear quickly. Flags and "verify by hand" results suggest which sources you should focus on in your review.
• A record. The results give you a citation-by-citation trail of what was checked.
• Inside Word. RealityCheck runs in the BriefCatch Word add-in and the BriefCatch Online App.

What doesn't it cover?

RealityCheck verifies case law. It identifies statutes, rules, regulations, record cites, and secondary sources but does not yet verify them, so the responsible attorney should check those directly. RealityCheck's coverage spans federal and state appellate case law. It flags some negative subsequent treatment, but pair it with KeyCite or Shepard's for full subsequent history. And for any authority RealityCheck can't locate, such  as copyrighted books and treatises, the responsible attorney checks the source directly.

The bottom line

SB 574 doesn't ask lawyers to stop using AI. It does make personal citation verification an express responsibility. Exactly how courts will apply that requirement, particularly when multiple attorneys work on a filing, remains to be seen. In the meantime, having one responsible attorney personally review every citation, quotation, and holding before filing is a conservative way to approach the new rule.

See it for yourself: Start a free, 7-day trial and run RealityCheck on your next filing.

‍This post is for general information and is not legal advice.

About Josephine Petrick

Josephine Petrick is Chief of AI Products at BriefCatch and a Partner and California State Bar-Certified Appellate Specialist at The Norton Law Firm PC.