Replays · Bankr. N.D. Ill. · July 18, 2025
A chapter 13 plan, a creditor's objection, and a response brief that quoted four bankruptcy decisions on creditor standing. The court looked each one up and set out what it found in a two-column table: what the brief claimed, and what exists.
The court found that counsel "cited four cases for a proposition of law, but none of them exist as alleged in his brief." (Memorandum Opinion, p. 6)
"lawyers blindly relying on generative AI and citing fake cases are violating Bankruptcy Rule 9011 and will be sanctioned." (Memorandum Opinion, p. 15)
| as filed | what the court said | what the register holds at this citation | our default check today | |
|---|---|---|---|---|
| 1 | In re Montoya, 341 B.R. 41 (Bankr. D. Utah 2006)Quoted in the filing: "[a] secured creditor's standing to object to confirmation is limited to issues that affect its rights directly." | In re Montoya exists, and the citation is correct. However, "not only does the language quoted by counsel not appear anywhere in the court's opinion, but the opinion does not address issues of standing at all." (p. 6) | In Re Montoya (Bankr. D. Utah 2006) | Check this Quoted language not in the opinion |
| 2 | In re Jager, 344 B.R. 349 (Bankr. D. Colo. 2006)Quoted in the filing: "not entitled to raise objections related to other creditors or the debtor's disposable income." | "In re Jager, 344 B.R. 349 (Bankr. D. Colo. 2006) does not exist." (p. 6) | No case starts at this page. It falls inside Official Committee of Unsecured Creditors of National Forge Co. v. Clark (In Re National Forge Co.) (W.D. Pa. 2006), which starts at 344 B.R. 340. | Check this Quoted language not in the opinionFlagged, but for the quotation. The page falls inside a different case, In re National Forge Co., which starts at 344 B.R. 340. The check did not compare that name with In re Jager; it compared the quoted words with that case's text. |
| 3 | In re Coleman, 373 B.R. 907 (Bankr. W.D. Wis. 2007)Quoted in the filing: "the plan proposes to alter the treatment of its secured claim in violation of §1325(a)(5)." | "not only does counsel's quotation not appear in the case at all, the opinion does not discuss the proposition for which it is cited, let alone support it." (p. 6)At this citation, per the court: In re Coleman, 373 B.R. 907, a case from the Bankruptcy Court for the Western District of Missouri, not Wisconsin (p. 6) | In Re Coleman (Bankr. W.D. Mo. 2007) | Check this Quoted language not in the opinion |
| 4 | In re Russell, 458 B.R. 731 (Bankr. E.D. Wis. 2011)Quoted in the filing: "A secured creditor's standing is limited to objecting to the treatment of its claim. It lacks standing to object to confirmation based on issues like feasibility or disposable income that do not directly impact its rights." | "Yet again, the quotation from counsel's brief does not appear anywhere in the court's opinion, and the opinion does not touch on the topic of standing at all." (p. 6)At this citation, per the court: In re Russell, 458 B.R. 731, a 2010 case from the Bankruptcy Court for the Eastern District of Virginia, not a 2011 case from Wisconsin (p. 6) | In Re Russell (Bankr. E.D. Va. 2010) | Check this Quoted language not in the opinion |
4 citations. Run September 24, 2026 with the default check, engine 0.5.0, register data of June 30, 2026: 4 Check this. 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.
All four rows would have been red. Three say the quoted words are not in the opinion the register holds at that cite, and the fourth, In re Jager, was flagged the same way, against the case the register holds at that page.
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.