Replays · D. Colo. · July 7, 2025
A defamation suit, and a defense opposition to a motion in limine filed shortly before trial. At a pretrial conference the court went through the brief's citations with counsel. Counsel said an earlier draft had been filed by mistake; the court found that the version counsel called final was substantially the same as the one filed, and sanctioned two lawyers.
"the Court identified nearly thirty defective citations in the Opposition." (Order to Show Cause, p. 3)
"These defects include but are not limited to misquotes of cited cases; misrepresentations of principles of law associated with cited cases, including discussions of legal principles that simply do not appear within such decisions" (Order to Show Cause, p. 3)
| as filed | what the court said | what the register holds at this citation | our default check today | |
|---|---|---|---|---|
| 1 | Mata v. City of Farmington, 798 F. Supp. 2d 1215, 1227 (D.N.M. 2011) | "the first misquotation in a parenthetical appearing on page 3 of the Opposition" (Order to Show Cause, p. 3) | Mata v. City of Farmington (D.N.M. 2011) | Found Found: Mata v. City of Farmington (D.N.M. 2011)The order does not reproduce the quoted words, so this replay could not run the quote check on them. |
| 2 | Ginter v. Nw. Mut. Life Ins. Co., 576 F. Supp. 627, 630 (D. Colo. 1984) | "a case from the United States District Court for the Eastern District of Kentucky became attributable to the United States District Court for the District of Colorado" (Order to Show Cause, p. 4) | Ginter v. Northwestern Mutual Life Insurance (E.D. Ky. 1984) | Found Found: Ginter v. Northwestern Mutual Life Insurance (E.D. Ky. 1984)The row names the court the register holds (E.D. Ky.). The default check does not compare that with the court in the citation. |
| 3 | Perkins v. Fed. Fruit & Produce Co., 945 F.3d 1242, 1251 (10th Cir. 2019) | The court asked counsel whether he would be surprised that the case "did not exist as an actual case", and later counted it among the "citations to non-existent cases" in the filed brief. (Order to Show Cause, p. 4)At this citation, per the court: United States ex rel. Alexander Volkhoff, LLC v. Janssen Pharmaceutica N.V., 945 F.3d 1237 (9th Cir. 2020), a False Claims Act case (Order to Show Cause, p. 4) | No case at this page. The register holds this volume. | Check this Not found in the register |
| 4 | World Wide Ass'n of Specialty Programs v. Pure, Inc., 450 F.3d 1132, 1138 (10th Cir. 2006) (recognizing that 'reputation and character are inextricably intertwined' in defamation cases) | "the quotation 'reputation and character are inextricably intertwined' does not appear in Pure." (p. 3) | World Wide Ass'n of Specialty Programs v. Pure, Inc. (10th Cir. 2006) | Found Found: World Wide Ass'n of Specialty Programs v. Pure, Inc. (10th Cir. 2006)The quotation sits in single quotes inside the parenthetical. The check did not read it as a quotation from the case, and at four content words it would be too short to check anyway, so the row reports the case only. |
| 5 | United States v. Reaves, 649 F.3d 862, 867-68 (8th Cir. 2011) | "Reaves does not support the proposition that '[c]ourts recognize that evidence often serves multiple purposes and implicates multiple evidentiary rules.'" (p. 3) | United States v. Reaves (8th Cir. 2011) | Found Found: United States v. Reaves (8th Cir. 2011) |
| 6 | Estate of Martinelli v. City & Cnty. of Denver, No. 19-cv-02737, 2021 WL 4133804, at *6-7 (D. Colo. Sept. 10, 2021) | One of "three citations to non-existent cases that were contained in the filed version". (p. 12) | A Westlaw number, not a page. No open register holds these. | Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it |
| 7 | United States v. Hoffman, 806 F.3d 1288, 1295 (10th Cir. 2015) | One of "three citations to non-existent cases that were contained in the filed version". (p. 12) | Richard M. Villarreal v. R.J. Reynolds Tobacco Company (11th Cir. 2015) | Check this Register holds a different case at this citation: Richard M. Villarreal v. R.J. Reynolds Tobacco Company (2015) |
| 8 | Perrin v. Anderson, 784 F.2d 1040, 1045 (10th Cir. 1986) | "Perrin is a civil rights, not defamation, case, and it says nothing about 'whether courts routinely admit evidence probative of truthfulness in defamation actions.'" (p. 15) | Perrin v. Anderson (10th Cir. 1986) | Found Found: Perrin v. Anderson (10th Cir. 1986)The court quotes this citation from counsel's corrected brief (Doc. 311-1) and says the error was discussed at the hearing on the filed one. |
| 9 | United States v. Hassan, 742 F.3d 104, 133 (10th Cir. 2014) | "misattributes United States v. Hassan, 742 F.3d 104, 133 (10th Cir. 2014) to the Tenth Circuit, when it is a case from the United States Court of Appeals for the Fourth Circuit." (p. 16) | United States v. Mohammad Hassan (4th Cir. 2014) | Found Found: United States v. Mohammad Hassan (4th Cir. 2014)The row names the court the register holds (4th Cir.). The default check does not compare that with the court in the citation. The court quotes this citation from the corrected brief (Doc. 311-1). |
9 citations. Run September 24, 2026 with the default check, engine 0.5.0, register data of June 30, 2026: 2 Check this, 1 Cannot verify, 6 Found. Each citation was pasted as a line of text (the quoted words first, where we have them) and checked the way the checker checks a draft: no language model, nothing stored. The register column is a direct lookup of the volume and page.
Two red rows (no case at 945 F.3d 1242 for Perkins, and a different case at 806 F.3d 1288 for Hoffman) and the Martinelli Westlaw number to check by hand. Most of what the court named is real cases that were misquoted or misdescribed, which the default check cannot see without the quoted words.
Paste the draft or upload the PDF. The default check reads every case citation and returns rows like the ones above in a few seconds, with no language model and nothing stored. It is free to try without an account. Then read what the court would read: every case you cite, at the page you cite.
Check a draft before you fileAll replays
Published September 24, 2026, updated September 24, 2026. We read the decision and copied the court's list; if we have misread it, write to hello@proofread.law. The rows are from the run dated above; they can change when the checker does.