On July 16, 2026, Chief U.S. District Judge Hala Y. Jarbou of the Western District of Michigan, a Trump appointee, admonished the Justice Department after finding that a government filing cited a court decision she could not find.
The filing was the government's response to an order to show cause in a habeas corpus petition brought by an ICE detainee, Izzeddin Ahmed Abdulghaffar Daghra, who was challenging the government's automatic stay of an immigration judge's $35,000 bond order. To argue that federal courts cannot “reweigh the evidence underlying a bond decision or second-guess the Immigration Judge's discretionary judgment,” the government cited Taylor v. Hott, 724 F. App'x 387 (6th Cir. 2018). Jarbou wrote that the cited page falls inside a commercial-arbitration case, and that the court “was unable to identify a Sixth Circuit case with the caption Taylor v. Hott, or any federal case containing the quoted language.” She concluded: “Thus, it seems this citation was likely produced by generative artificial intelligence.”
“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,” Jarbou wrote. She noted “a rash of cases” involving fabricated authorities but declined to impose sanctions, writing that “it goes without saying that the Government must ensure its future filings with this Court do not include non-existent case law.” In the same three-page order she dismissed Daghra's petition as moot, because the stay had expired and the government said he could be released upon posting the $35,000 bond. Bloomberg Law reported that the docket shows the response was filed by an assistant U.S. attorney in the Western District of Michigan.
It was not isolated. In April 2026, a North Carolina magistrate judge publicly reprimanded a former federal prosecutor who admitted using generative AI in a brief that contained false quotations and erroneous citations, Newsweek reported.
The government was arguing to keep a man detained, and the authority it cited for that position could not be found. The Justice Department received a warning, not a sanction.
Correction (October 2, 2026): This entry said Daghra was released after posting a $35,000 bond. The order and the coverage say only that the government stated he could be released upon posting that bond, and the case was dismissed as moot. It also spelled his name as it appeared in one news report; the court docket spells it Abdulghaffar. An unsourced claim that a private litigant would have faced sanctions was removed.