Replays · N.D. Ala. · July 23, 2025
Two discovery motions filed for a former state prison commissioner, sued by an incarcerated plaintiff. The plaintiff told the court that citations in the motions could not be found, and three defense lawyers confirmed that ChatGPT had produced them. There was no fine. The court publicly reprimanded the three, removed them from the case and referred them to the state bar.
"In simpler terms, the citations were completely made up." (Sanctions Order, p. 1)
"Any reasonable investigation (indeed, even the most cursory of investigations, or a spot check) would have quickly revealed the problem." (Sanctions Order, p. 38)
"In total, there were five problematic citations across two motions:" (Sanctions Order, p. 4)
| as filed | what the court said | what the register holds at this citation | our default check today | |
|---|---|---|---|---|
| Motion for leave to depose the plaintiff (Doc. 174 at 2) | ||||
| 1 | United States v. Baker, 539 F. App'x 937, 943 (11th Cir 2013) | "And the case found in the Federal Appendix numbers cited by Defendant Dunn does not discuss discovery." (p. 4)At this citation, per the court: Williams v. Morahan, 539 F. App'x 937 (11th Cir. 2013) (p. 4) | No case starts at this page. It falls inside Williams v. Morahan (11th Cir. 2013), which starts at 539 F. App'x 934. | Check this Register holds a different case at this citation: Williams v. Morahan (2013) |
| 2 | Kelley v. City of Birmingham, 2021 WL 1118031, at *2 (N.D. Ala. Mar. 24, 2021) | "The only case with that style which Plaintiff Johnson (and the court) could find was an Alabama Court of Appeals case from 1939 that dealt with a traffic offense." (p. 4) | A Westlaw number, not a page. No open register holds these. | Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it |
| 3 | Greer v. Warden, FCC Coleman I, 2020 WL 3060362, at *2 (M.D. Fla. June 9, 2020) | "This case does not exist, nor does a case exist with a similar citation for that proposition of law." (p. 5) | A Westlaw number, not a page. No open register holds these. | Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it |
| 4 | Wilson v. Jackson, 2006 WL 8438651, at *2 (N.D. Ala. Feb. 27, 2006) | "There is no such case, and that Westlaw number directs to a maritime personal injury case that does not discuss discovery." (p. 5)At this citation, per the court: Douglas v. Ingram Barge Co., 2006 WL 8438651 (S.D.W. Va. Sept. 15, 2006) (p. 5) | A Westlaw number, not a page. No open register holds these. | Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it |
| Motion to compel (Doc. 182 at 13) | ||||
| 5 | Williams v. Asplundh Tree Expert Co., No. 3:05-cv-479, 2006 WL 3343787, at *4 (M.D. Fla. Nov. 17, 2006) | "Though a case with that style exists, no case with that combination of style and proposition exists." (p. 5) | A Westlaw number, not a page. No open register holds these. | Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it |
5 citations. Run September 24, 2026 with the default check, engine 0.5.0, register data of June 30, 2026: 1 Check this, 4 Cannot verify. 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.
One row would have been red before filing: the register holds Williams v. Morahan, not United States v. Baker, at 539 F. App'x 937. The other four are Westlaw numbers, which no open register can look up, so the report would have listed them for a Westlaw check. The court wrote that even a spot check would have revealed the problem.
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.