Replays · S.D. Ind. · May 28, 2025
The magistrate judge could not locate a Seventh Circuit case cited in a defense brief and ordered counsel to file a copy. Counsel could not find it either, and a look at counsel's earlier briefs turned up two more citations the judge could not locate. Counsel admitted using AI to draft all three briefs.
"Transposing numbers in a citation, getting the date wrong, or misspelling a party's name is an error. Citing to a case that simply does not exist is something else altogether." (Order to Show Cause, p. 1)
The magistrate judge added that "the use of artificial intelligence must be accompanied by the application of actual intelligence in its execution." (Report and Recommendation, p. 6)
| as filed | what the court said | what the register holds at this citation | our default check today | |
|---|---|---|---|---|
| 1 | In re Cook County Treasurer, 773 F.3d 834 (7th Cir. 2014) | "a case the Undersigned was unable to locate" (Report and Recommendation, p. 1) | No case at this page. The register holds this volume. | Check this Not found in the registerCited in Dkt. 65 at 5. Counsel's notice later "acknowledge[d] that the referenced citation was in error" (Report and Recommendation, p. 1). |
| 2 | Knoedler Manufacturers, Inc. v. Cox, 545 F.2d 1033, 1035 (7th Cir. 1976) | "two other citations that the Court is unable to readily locate" (Order to Show Cause, p. 2) | No case at this page. The register holds this volume. | Check this Not found in the registerCited in Dkt. 39. |
| 3 | Brown v. Local 58, IBEW, 628 F.2d 441 (6th Cir. 1980) | "two other citations that the Court is unable to readily locate" (Order to Show Cause, p. 2) | Robert Avery, Cross-Appellants v. Maremont Corporation, Cross-Appellee (5th Cir. 1980) | Check this Register holds a different case at this citation: Robert Avery, Cross-Appellants v. Maremont Corporation, Cross-Appellee (1980)Cited in Dkt. 52. |
3 citations. Run September 24, 2026 with the default check, engine 0.5.0, register data of June 30, 2026: 3 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.
Three red rows, one for each brief: the register has no case at 773 F.3d 834 or at 545 F.2d 1033, and it holds a different case (Robert Avery v. Maremont Corporation) at 628 F.2d 441.
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.