Federal Judge Criticizes DOJ for AI-Generated Citation

A federal judge in Michigan criticized the Department of Justice during the Trump administration for citing a nonexistent court decision in an immigration detention case. The citation appeared to be generated by artificial intelligence, as indicated by court filings.

Chief U.S. District Judge Hala Y. Jarbou from the Western District of Michigan addressed the issue in a three-page order issued on July 16. The order related to a habeas corpus case brought by Izzeddin Ahmed Abdulgahffar Daghra, an Immigration and Customs Enforcement (ICE) detainee. Daghra’s case challenged the government’s automatic stay of a bond order.

Although the judge dismissed the case as moot, after the stay expired and the government allowed Daghra’s release upon posting a $35,000 bond, she took particular issue with a citation in the DOJ’s filing. Government lawyers had claimed that the Sixth Circuit prevented federal courts from reviewing or questioning the evidence behind a bond decision, citing a nonexistent case: Taylor v. Hott.

The situation underscores the ongoing tensions between the judiciary and the Trump administration, as federal judges often scrutinize actions taken by the federal government. Judge Jarbou stressed that attorneys using AI must verify their work thoroughly before submitting court documents.

Jarbou highlighted an increasing number of cases with AI-fabricated authorities, noting that courts frequently encounter briefs with non-existent, “hallucinated” cases. She stated, “It should be obvious 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.”

While not imposing sanctions, the judge cautioned the government to avoid filing documents with fictitious legal authorities in the future.

The Michigan case isn’t the only instance where the Justice Department faced issues with AI-generated legal filings. In April, U.S. Magistrate Judge Robert T. Numbers II in North Carolina reprimanded former federal prosecutor Rudy Renfer. Renfer admitted using AI in a court brief that included false quotations, inaccurate citations, and misrepresented case law.