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Federal · federal court of appeals · 2026

Lichfield v. Kubler

Court of Appeals for the Tenth Circuit, 27 July 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · 10th Cir.

  1. Court. Court of Appeals for the Tenth CircuitCOURT
  2. Level. federal court of appealsLEVEL
  3. Date. 27 July 2026DATED
  4. Docket. No. 25-4135DOCKET
  5. Documents. one document, 3 passages quoted belowON FILE
  6. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 27 July 2026 · source · PDF · 47 pages

E Finally, we address an issue that only became operative on appeal. In his Opening Brief, Lichfield included citation to a legal authority that does not exist, see Op. Br. at 39, and characterized two cases in manners wholly unsupported by the text of the opinions, see Op.

Id. This court has recently issued sanctions for the use of generative artificial intelligence that resulted in the filing of a brief with citations to seven cases that do not exist and two cases that do exist but do not contain the quotations that the briefing alleged. Amarsingh v.

But it should not have taken questioning at argument to elicit such a response. Submission of a brief containing fabricated or hallucinated citations is a divergence from the standards expected of attorneys appearing before this court. Any such error should be corrected explicitly and without prompting.

What the text mentions

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Where this fits

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More from Court of Appeals for the Tenth Circuit, from Federal, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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