# Church of Scientology Wants Someone Else Punished for Making Stuff Up > Source: > Published: 2026-07-17 21:45:57+00:00 1. Does a court have discretion to ignore an attorney’s admitted abuse of artificial intelligence that violated the California Rules of Court, or is the court required to resolve whether to sanction that attorney and explain the reasoning for its decision? 2. Does it matter that the party demanding sanctions reportedly teaches people that they are afflicted by disembodied souls that were stolen 75 million years ago by the [Emperor Xenu], ruler of the Galactic Confederacy, who brought billions of his subjects to Earth in spaceships that looked like DC-8s, put them around volcanoes he then blew up with hydrogen bombs, releasing the souls and causing problems to this day that only expensive Scientology classes can solve? The first of these questions is taken from the [petition for review in Bixler v. Church of Scientology International](https://www.law360.com/pulse/articles/2494348/attachments/0), now pending before the California Supreme Court. The second one is just a question I personally have. As [Law360 reported on June 26](https://www.law360.com/pulse/articles/2494348/scientologists-want-ignored-boies-schiller-ai-errors-review), the Church of Scientology (which I will call “Scientology” or “CSI” so I don’t have to keep putting quote marks around “church”) and related defendants are fighting claims by five women who say it directed a “relentless campaign of harassment, surveillance, threats, and defamation” at them after they accused a prominent CSI member of rape. Defendants filed a motion to strike, the motion was granted but only in part, and so they appealed that ruling. The Court of Appeal affirmed. The decision allows the plaintiffs’ claims to proceed. But they won despite the revelation that their lawyers used AI to “help” write the brief, didn’t check the results, and so filed a brief with cites that were wrong, mischaracterized, or just made up. Further showing the unsupervised-AI problem is afflicting the profession as a whole, this is another case involving a big, well-known law firm (Boies Schiller Flexner). The Court of Appeal told Boies Schiller it was considering sanctions. In its response, the firm admitted the mistakes and said … well, all the things that lawyers say when this happens. Ultimately, the court ruled on the appeal but didn’t say anything about sanctions. Defendants wanted to know why. “The Church is unaware of a single court that has declined to impose sanctions when confronted with clear evidence of artificial intelligence abuse,” it said in a petition for rehearing. So why not here? The court denied that petition without explanation (or any comment on the defendants’ inexplicable failure to hyphenate “artificial-intelligence abuse”). Unsatisfied, CSI filed a petition asking the California Supreme Court to review the matter, raising two questions. The first, as shown above, asks whether a court faced with an undisputed misuse of AI (or, presumably, fabricated citations from any source) can just ignore it without at least explaining its reasons. I think the answer is probably yes, unless there’s evidence it abused its discretion. But the only thing CSI cites along those lines is not evidence but the claim that it’s “unaware of” any other case in which this has happened. That doesn’t prove there is no such case. It doesn’t even prove that they *looked *for such cases (although they or their lawyers may well have). For that and other reasons I’d be surprised if the court grants review on that question. The petition’s second question is **not** the one above, but a First Amendment question on the merits. The plaintiffs allege CSI has a doctrine called “Fair Game,” which says that anyone who leaves Scientology is declared an enemy and “fair game” for harassment. CSI denies that it has any such doctrine. The original motion required the plaintiffs to offer some evidence to support the claim, and the Court of Appeal held they offered enough to go forward. According to the court, this was partly because a CSI representative “confirmed in a declaration that ‘Fair Game’ was formerly an authorized Scientology doctrine, although it is no longer an express policy.” CSI takes issue with this, saying it admitted it once had * a *doctrine that “was *not*‘Fair Game'”—without explaining what it was—but this non-Fair-Game doctrine was “cancelled in 1968.” Its second question is therefore (in part) whether the First Amendment allows a court “to rely on a purported religious doctrine of a minority religion as evidence against a church even though the church’s duly constituted ecclesiastical leadership has disavowed the existence of the purported doctrine….” So CSI seems to be arguing that if its leaders *say*it doesn’t do something, a court has to take its word for that because otherwise it would be interfering in religious doctrine. I’m skeptical about that but it might be a question the California Supreme Court would consider. But my interest in this is really the continuing train wreck that reliance on AI is causing in the legal profession. AI has its uses. But in legal research or brief writing, its output *cannot be trusted. *If you don’t believe that, trust it and see what happens. Boies Schiller did. It’s not alone by any means, though it *might* be alone in escaping sanctions. But it is surely alone in the category of Firms That Have Been Successfully Humiliated for Making Things Up by *the Church of Scientology*, for God’s Sake. I mean, if you find yourself even in the general vicinity of being considered *less credible* than the Church of Scientology, even on a limited issue, you might want to think hard about what got you there. Remember, Scientology was founded by a science-fiction writer, and not a good one, either. From time to time, CSI representatives have denied the Xenu story summarized above (and on this [Emmy-nominated episode of South Park](https://en.wikipedia.org/wiki/Trapped_in_the_Closet_(South_Park))), but I’m not aware that CSI’s duly constituted ecclesiastical leadership has ever disavowed it. And there is evidence the Xenu nonsense is still doctrine, even though you have to make it to “Operating Thetan Level III,” after paying the appropriate fee, before getting the details. And yet, at least in one battle, AI forced somebody to yield the high ground in terms of credibility to *these*guys. That is not a position you want to find yourself in.