Courts on AI / Fabricated or misquoted citations

Perez-Castillo v. Blanche

United States Court of Appeals for the Seventh Circuit · Federal courts of appeals · 2026-06-01 · No. No. 25-1988 · opinion

Fabricated or misquoted citations Competence, fees and billingChatGPT

On 2026-06-01, in Heriberto Perez-Castillo v. Todd W. Blanche, the Seventh Circuit sanctioned counsel for appellate expenses, admonished him, and referred the matter for possible discipline. Counsel filed an opening brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and authorities used for propositions they did not support.

Disposition: The court denied the petition for review, imposed a $5,000 sanction on counsel, and referred the matter to the Illinois Attorney Registration and Disciplinary Commission.
Recorded conduct: Attorneys Salah and Chalisa filed an opening brief with about two dozen fabricated quotations, seven nonexistent circuit cases, and legal and factual errors after using ChatGPT/AI-assisted drafting or review. The court imposed $5,000 and made a disciplinary referral. — outcome: regulatory referral; actor: lawyer; $5,000
Canonical record: Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Perez-Castillo’s opening brief was riddled with AI hallucinations. These included two 2 No. 25-1988 dozen fabricated quotations, seven cases wrongly identiﬁed as precedent from this circuit, erroneous legal propositions, and assertions of fact ﬂatly contradicted by the record. Counsel for Perez-Castillo, Abdullah Salah, blamed these errors on another attorney with whom he had contracted to write the brief. That attorney, Farah Chalisa, did not enter an appearance in this case. In Salah’s telling, Chalisa used ChatGPT for “stylistic and grammatical review” that resulted in the hallucinations. To better understand what happened, we issued an order to show cause why both attorneys should not be sanctioned for their conduct. Both Salah and Chalisa responded, oﬀering their respective sides of the story. Onthemerits,wedenyPerez-Castillo’spetitionforreview because it cannot succeed as a matter of law. As for attorney Salah, we impose a ﬁne of $5,000 for violating this court’s rules of professional conduct and multiple Federal Rules of Appellate Procedure.

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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