loupe.legal

Guides

Fabricated citations: how to tell before you file.

A fabricated citation has the shape of a real one, and the reporters are dense enough that an invented volume and page usually lands on a real opinion, just not the one named. So the citation’s existing proves nothing; the record has to be read.

Written 5 November 2026. Loupe reports what the sources say; it is not legal advice.

Why they look right

A language model has read a great many citations and reproduces their shape perfectly: parties, a reporter, a volume, a page, a year, a court.

What it has not done is open the volume. The reporters are dense: a volume of the Federal Reporter holds some hundreds of opinions, so a volume and page chosen to look right usually fall inside a real opinion, under a different name. A checker that stops at “the citation exists” passes the fabrication. The question is never whether 912 F.3d 1104 is a page; it is whose opinion begins there, and whether that is the case the brief names.

Six tells

  • The page belongs to another case

    The opinion that begins at the cited page has different parties. This is the tell that settles most fabrications, and it needs the record, not the brief.

  • The name and the citation disagree

    The parties are real and litigated something, but not at that citation; or the name is a blend of two cases.

  • The year does not fit the volume

    Volumes are printed in order. A 2019 decision in a volume printed in 2012 is not a decision.

  • The court does not publish there

    A state trial court in the Federal Reporter; a circuit in a state reporter; a district court in F.3d.

  • The quotation cannot be found

    A composed quotation is the commonest companion of a composed case, and also of a real case that does not say it. Verifying a quotation.

  • The holding is exactly what the brief needs

    A case that disposes of the hard issue in one clean sentence, that nobody on either side has cited before, is worth opening first.

What courts have done

Sanctions first, then rules that put the verification into the signature.

The sanctions decisions began in 2023, with a federal court in New York sanctioning lawyers whose brief cited cases that did not exist, and have been collected since, decision by decision, in Damien Charlotin’s database. In 2026 the rules followed: Florida’s signers now represent that the authorities they cite exist and are accurately cited, Indiana’s that cited authority is authentic, California’s may not file a citation the responsible attorney has not personally verified, and dozens of federal judges have standing orders of their own. Each is quoted from the court’s document, with its date, on the court pages; the statewide rules of 2026 are in one guide.

What to do

  • Check every citation, not the suspicious ones

    The fabrications that reach a court are the plausible ones. A check that looks only at what seems odd is a check of the checker’s intuition.

  • Check against the record, not against another model

    Asking a second assistant whether a case is real produces a second opinion of the same kind. The reporter is not an opinion.

  • Keep the record of the check

    What was checked, against what, on what day. If a court asks what was done before the signature, the answer is written down.

  • Read what is still open

    A citation the record could not settle is not a fabrication and not a clean one. It is unread.

What Loupe does

Every citation is looked up in Loupe’s own index of the reporters and at the publishers’ sites, and the report says what the record holds at that citation.

A case is reported as holding up only when the opinion at that citation exists and is the one the brief names, with its year and court, and the pin cite falls inside its pages. A citation whose page belongs to another case is reported with that case’s name, so the fabrication is visible rather than merely flagged. What the sources cannot settle is reported as not verified. And because calling a real case fake costs a lawyer more than missing a bad one, how often Loupe accuses a real citation is measured on named documents and published, re-run with every release.

Check a filing

Paste the brief or drop the file, and Loupe looks up every citation in the published record. It doesn’t generate anything, and what it can’t settle it marks “not verified”, never clean.