Danuta Dec v. Homeland Security
7th Cir. CA · Mar 30, 2026
What happened in this matter?
The Seventh Circuit admonished petitioner's counsel for including non-existent case citations and a false quotation in an opening brief. While the court noted the errors were characteristic of AI-generated content, it accepted counsel's apology and lack of intent to deceive, ultimately declining to impose further sanctions beyond the public admonishment.
- Why the court cared
- The court reasoned that while the errors were consistent with AI-generated hallucinations, counsel's sincere apology, acceptance of responsibility, and lack of intent to deceive warranted only a public admonishment rather than formal disciplinary sanctions.
- Why it matters now
- Counsel who 'cannot explain' a fabricated cite when questioned escalate admonishment into discipline risk.
Why this matter is tracked
In Danuta Dec v. Homeland Security, the Seventh Circuit Court of Appeals addressed an opening brief containing non-existent case citations and a false quotation. The court noted these errors were seemingly generated by artificial intelligence, though counsel denied using AI, attributing the errors to copying and pasting from an unlocatable prior brief. The court found the counsel's lack of explanation for the fabricated citations concerning but accepted her contrition and lack of intent to deceive. Consequently, the court issued a public admonishment to counsel for failing to verify the accuracy of legal authorities, emphasizing the professional duty of honesty and vigilance in all filings. The court declined to impose further sanctions, noting the errors were limited and did not impact the case's outcome.
Counsel who 'cannot explain' a fabricated cite when questioned escalate admonishment into discipline risk.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Appellate review of a district court dismissal for lack of subject-matter jurisdiction; the court addressed the briefing errors as a collateral matter within the appellate opinion.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Opening brief included a false quotation (an imaginary quote) attributed in support of the standard of review; court found the quotation was inaccurate and likely AI-generated.
- Fabricated: Case Law | Opening brief cited a non-existent case (first instance); court identified it as a fabricated citation likely from AI and counsel could not explain its source.
- Fabricated: Case Law | Opening brief cited a second non-existent case; court treated this as another fabricated citation and noted counsel's inability to account for it.
Questions this record answers
- What happened in Danuta Dec v. Homeland Security?
- The Seventh Circuit admonished petitioner's counsel for including non-existent case citations and a false quotation in an opening brief. While the court noted the errors were characteristic of AI-generated content, it accepted counsel's apology and lack of intent to deceive, ultimately declining to impose further sanctions beyond the public admonishment.
- Why does Danuta Dec v. Homeland Security matter for legal AI risk?
- Counsel who 'cannot explain' a fabricated cite when questioned escalate admonishment into discipline risk.
- What does the public record establish about Danuta Dec v. Homeland Security?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Danuta Dec v. Homeland Security summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.