A federal judge in Michigan has strongly criticized the Trump administration’s Department of Justice for an alleged AI-generated citation in a legal filing related to an immigration detention case. The legal document, which cited a nonexistent court decision, raised significant concerns.
Chief U.S. District Judge Hala Y. Jarbou, overseeing the Western District of Michigan, highlighted the issue in a July 16 order for a habeas corpus case. This case involved an ICE detainee, Izzeddin Ahmed Abdulgahffar Daghra, challenging the government’s automatic stay of a bond order. Though the judge dismissed the case as moot, the move followed the government’s announcement that Daghra could be released upon posting a $35,000 bond.
Trump’s DOJ Alleged of Using Nonexistent Court Citation
Judge Jarbou specifically addressed a citation in the DOJ’s filing. Government lawyers argued that the Sixth Circuit had previously decided federal courts cannot reevaluate evidence linked to a bond decision or reassess an Immigration Judge’s judgment, referencing the case Taylor v. Hott, which reportedly does not exist.
This incident underscores the tensions between the judiciary and the Trump administration. Federal judges are increasingly scrutinizing actions taken by the government, sometimes issuing strong rebukes. Judge Jarbou emphasized the responsibility of legal professionals using AI, insisting they verify their work diligently before submitting documents to the court.
“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,” Judge Jarbou stated.
Although she opted against imposing sanctions, Jarbou warned that future government filings must avoid citing nonexistent legal authorities.
The Michigan case is not isolated. Previously, in April, U.S. Magistrate Judge Robert T. Numbers II in North Carolina censured former federal prosecutor Rudy Renfer for using generative AI in a legal brief. Renfer’s filing contained false quotations, erroneous citations, and mischaracterizations of case law, further amplifying concerns regarding AI-generated legal work.