About

7th Circuit Admonishes Ex-Judge Attorney for Bogus AI Citations

Published
Score
19

Why it matters

The Seventh Circuit Court of Appeals declined to sanction attorney and former chief federal immigration judge Heriberto Perez-Castillo for submitting a brief containing two fabricated cases and a false quotation in Perez-Castillo v. Todd W. Blanche. The court called the errors an "astonishing number of erroneous and even hallucinated citations"—hallmarks of AI generation—but accepted Perez-Castillo's denial of AI use as plausible given that the errors were few in number and strategically useless to his argument.

The court issued a public admonishment but imposed no formal sanctions. This outcome diverges from a separate June 2026 Seventh Circuit ruling where attorney Salah faced a $5,000 fine for similar AI hallucinations. The panel also signaled that opposing counsel do not yet have a formal duty to audit an adversary's citations, though the court suggested courts expect shared vigilance on the issue going forward.

Attorneys should treat this as a warning, not a reprieve. The ruling reinforces that citation verification remains non-delegable regardless of whether AI assisted in drafting. Federal courts are drawing inconsistent lines on AI sanctions—some imposing fines, others public admonishment—but all are holding lawyers accountable for accuracy. The practical takeaway: outsourcing to AI does not reduce a lawyer's obligation to verify every citation before filing.

Sources

mail Subscribe to Law And Technology email updates

Primary sources. No fluff. Straight to your inbox.

Also on LawSnap