Judge Criticizes DOJ Lawyer for AI-Hallucinated Fake Case Citation
Judge Hala Jarbou faulted DOJ counsel for filing a fake case citation likely from AI.
Why it matters: This highlights rising judicial scrutiny on AI use in legal filings and stresses attorneys must verify AI-generated content to maintain legal accuracy and integrity.
- On July 16, 2026, Judge Hala Jarbou criticized DOJ for citing a non-existent case in court filings.
- The fake citation was 'Taylor v. Hott, 724 F. App'x 387, 392 (6th Cir. 2018)', related to an ICE detainee's habeas corpus petition.
- Judge Jarbou warned attorneys to rigorously check AI-generated work products for accuracy.
- In June 2026, two immigration attorneys were suspended and fined for submitting briefs with AI-generated fake cases in the Ninth Circuit.
Chief U.S. District Judge Hala Jarbou of the Western District of Michigan publicly reprimanded the Department of Justice on July 16, 2026, for submitting legal filings in an immigration case that contained a fabricated citation likely produced by artificial intelligence. The non-existent case cited was Taylor v. Hott, 724 F. App'x 387, 392 (6th Cir. 2018), associated with an Immigration and Customs Enforcement detainee, Izzeddin Ahmed Abdulghaffar Daghra, who filed a writ of habeas corpus in May 2026.
Judge Jarbou emphasized the imperative for attorneys to thoroughly verify any AI-generated legal assertions, stating, "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."
This incident comes amid growing concerns about "hallucinations" — AI fabricating plausible but false information. In a related disciplinary matter, two Orange County immigration attorneys, Mike Singh Sethi and William Rounds, were suspended for six months and fined $2,500 each by the Ninth Circuit Court of Appeals in June 2026 for filing briefs with multiple non-existent cases and misattributed quotations, also linked to AI-generated errors.
These developments underscore the critical need for legal professionals to exercise caution when integrating AI tools into litigation practice. With over 3.3 million cases pending before U.S. immigration courts as of early 2026, the reliability of factual and legal assertions in filings remains paramount to the justice system's integrity.
Attorney Alissa Heynen of Michigan Immigrant Rights highlighted the risks, stating, "Relying on fabricated cases... undermines the credibility of legal advocacy and can have serious implications for clients." Although Judge Jarbou did not sanction the DOJ lawyer in this specific instance, her public criticism sends a clear message about the risks of AI misuse in the courtroom.
By the numbers:
- $2,500 — fine imposed on each attorney suspended in the Ninth Circuit for AI-generated filing errors
- 6 months — suspension duration for two Ninth Circuit immigration attorneys who filed AI-hallucinated briefs
- 3.3 million — number of pending cases before U.S. immigration courts as of February 2026