Flora Chumpitaz-Morales v. Pamela J. Bondi
10th Cir. CA · Feb 11, 2026
- Jurisdiction
- federal
- Court
- 10th Cir. CA
- Record ID
- flora-chumpitaz-morales-v-pamela-j-bondi-2026-02-11
- Observed outcome
- The court issued a warning regarding the use of AI in legal filings but declined to impose formal sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Tenth Circuit issued a warning to a pro se litigant after discovering that her appellate brief contained AI-hallucinated case citations. The court declined to impose formal sanctions, noting the government's failure to request them, but explicitly cautioned that all litigants must verify their filings to avoid misrepresenting legal authority.
Misrepresented: Case Law | Brief appears to include citations that 'bear no relationship to the propositions for which they are cited,' suggesting possible fabricated case citations added by an AI product; government identified one problematic citation (not specified). || Misrepresented: Case Law | Petitioner's brief misrepresents the holdings of several cases it cites; the court attributed these misrepresentations to AI hallucination.
This record documents a Pro Se Litigant filing issue in 10th Cir. CA, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Misrepresented Authority
- Immigration
- Appellate
- Warning
- AI attribution
- Implied
- Recorded tool
- unspecified AI product
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a Board of Immigration Appeals (BIA) final order of removal.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court suspected the use of an AI product like ChatGPT or Microsoft CoPilot.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.