Federal Judge Criticizes DOJ for AI-Generated Citation in Immigration Case

A federal judge in Michigan criticized the Department of Justice (DOJ) under the Trump administration for including an alleged false court citation in a legal filing. This was potentially generated by artificial intelligence. The issue surfaced in a habeas corpus case involving an Immigration and Customs Enforcement (ICE) detainee.

On July 16, Chief U.S. District Judge Hala Y. Jarbou of the Western District of Michigan issued a three-page order highlighting the problem. The case, brought by detainee Izzeddin Ahmed Abdulgahffar Daghra, challenged the government’s automatic stay of a bond order. Daghra’s case became moot after the stay expired, allowing for his release on a $35,000 bond.

DOJ Cited Nonexistent Case

Judge Jarbou pointed to a DOJ citation in their filing claiming that the Sixth Circuit held federal courts cannot “reweigh the evidence underlying a bond decision or second-guess the Immigration Judge’s discretionary judgment.” The citation was for Taylor v. Hott, a case that does not exist.

Judicial Scrutiny of AI Tools

This situation highlights growing tension between federal judges and the Trump administration, with courts increasingly critical of government actions. Jarbou emphasized that attorneys using AI tools must verify their work thoroughly before submitting court documents.

The judge warned, “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.”

Warnings Against AI Errors

While the judge did not impose sanctions, she stressed the need for the government to prevent future filings from containing nonexistent legal authorities. This Michigan case is not isolated. In April, U.S. Magistrate Judge Robert T. Numbers II in North Carolina criticized former federal prosecutor Rudy Renfer for using generative AI in a court brief, resulting in false quotations and errors.