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AII-1000-33273
ConfirmedA court, a regulator or the organization itself has stated the core facts, or the record cites a court or regulator source.Supporting sources are pending verification.

Judge rebukes DOJ for fabricated legal citation in immigration case

The U.S. Department of Justice filed a legal brief containing a fabricated case citation that a federal judge found was likely generated by artificial intelligence. The judge warned the DOJ to ensure future filings do not include non-existent case law but declined to impose sanctions.

May 2026 Β· Todd Blanche Β· Reliability and hallucination
May 2026
AII-1000-33273
Quick facts
Category
Reliability and hallucination
Country
United States
Date
May 2026
Drafted by
Raidu Incident Detection

What happened

In May 2026, the U.S. Department of Justice filed a legal brief in an immigration bond case involving an ICE detainee named Izzeddin Daghra. The brief cited a Sixth Circuit case called Taylor v. Hott to argue the court lacked authority to intervene in the government's appeal of a $35,000 bond decision.

Chief U.S. District Judge Hala Jarbou of the Western District of Michigan found the citation did not exist. The cited page of the Federal Appendix actually contained an unrelated ruling about commercial arbitration, and no federal case with the caption Taylor v. Hott could be found anywhere. The judge determined the citation 'seems likely produced by generative artificial intelligence.'

Reported impact

The judge issued a warning that the government must ensure future filings do not include non-existent case law but did not impose sanctions at that time.

Index analysis

Generative AI models can produce fabricated citations that appear plausible but do not correspond to actual legal cases, a phenomenon known as 'hallucination.' The cited case Taylor v. Hott did not exist in any federal reporter.

Governance controls

The judge noted that 'any attorney who uses AI must scrupulously review its work product to ensure that the cited cases exist and that the citations accurately and fairly represent the underlying case law,' emphasizing the duty of candor required of government counsel.

Classification

Category
Reliability and hallucination
Industry
Government, security and defence
Country
United States
Harm status
Potential harm
Intent
Unintentional
Timing
Post-deployment
Harmed
Government
Failure modes
Fabricated citation, Hallucination
Consequences
None recorded
AI systems
Generative AI

Sources and evidence

Sources not yet published

This record was researched and written by the Index from original reporting. Its sources are still being verified by an editor, and they are listed here once that check is complete. Until then the record carries no reviewer.

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