Courts on AI / Fabricated or misquoted citations
Heriberto Perez-Castillo v. Todd W. Blanche
United States Court of Appeals for the Seventh Circuit · Federal courts of appeals · · No. 25-1988 · order
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 sanctioned counsel for appellate expenses, admonished him, and referred the matter for possible discipline.
- Recorded conduct
- 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. — outcome: referral; actor: lawyer; $4,997
- 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.
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