Sanction teardown · 5th Cir. CA, USA · 2026-08-14
Guerra-Quezada v. United States; Guerra-Vasquez v. United States (consolidated)
What happened
In 5th Cir. CA, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:
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False Quotes (Case Law)Briefs quote Ng Fung Ho for the sentence '[N]o deportable alien may be expelled until it has first been determined . . . that he is in fact an alien,' but the court's research could not locate that quote in Ng Fung Ho or any opinion.
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False Quotes (Case Law)Briefs attribute the phrase '[i]t is wrong to deport a United States citizen' to Ng Fung Ho though that phrase does not appear in the opinion.
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Misrepresented (Case Law)Counsel cited Doe v. McAleenan as a Fourth Circuit opinion, but the decision is actually a Seventh Circuit opinion and begins on a different page of the Federal Reporter.
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False Quotes (Case Law)A quotation the briefs attribute to Afroyim v. Rusk actually originates from a dissent in Perez v. Brownell (Warren, C.J., dissenting).
Which AI tool
an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.
Outcome
Warning
How Citation Safe would have caught this
Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.
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Source: https://www.damiencharlotin.com/documents/2900/Quezada_v._USA_USA_14_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).