Heriberto Perez-Castillo v. Todd W. Blanche
7th Cir. CA · Jun 1, 2026
What happened in this matter?
The court imposed a $5,000 monetary sanction on attorney Abdullah Salah under Federal Rule of Appellate Procedure 46(c) for failing to verify AI-generated content in his filings. The court also admonished the assisting attorney, Farah Chalisa, and referred both attorneys to the Illinois Attorney Registration and Disciplinary Commission for further investigation into potential ethical and professional conduct violations.
- Why the court cared
- The court reasoned that Salah's failure to review the brief before signing and submitting it, despite certifying its accuracy, constituted egregious misjudgment and conduct unbecoming of a bar member, warranting sanctions under Rule 46(c).
- Why it matters now
- This case illustrates the severe consequences for lead counsel who fail to verify AI-assisted filings. It highlights that outsourcing research to non-appearing counsel does not absolve the signing attorney of the duty to ensure the accuracy of all citations and factual assertions.
Why this matter is tracked
The Seventh Circuit sanctioned attorney Abdullah Salah $5,000 for filing appellate briefs containing approximately 24 fabricated quotations, seven mislabeled or nonexistent cases, and factual assertions contradicted by the record. Salah outsourced the brief's preparation to attorney Farah Chalisa, who used ChatGPT for stylistic review and inadvertently introduced AI hallucinations. Salah admitted he did not review the brief before signing and submitting it, nor did he adequately verify the revised version after the court issued an order to show cause. While the court declined to sanction Chalisa, it admonished her for the resulting confusion and referred the matter to the Illinois Attorney Registration and Disciplinary Commission to investigate potential ethical violations regarding fee-splitting and the accuracy of her representations.
This case illustrates the severe consequences for lead counsel who fail to verify AI-assisted filings. It highlights that outsourcing research to non-appearing counsel does not absolve the signing attorney of the duty to ensure the accuracy of all citations and factual assertions.
Record details
What the record establishes about AI use
Attorneys admitted using ChatGPT for stylistic review.
The court issued an order to show cause regarding the use of generative AI in an appellate brief, reviewed responses from counsel, and subsequently issued a final opinion denying the petition for review while imposing sanctions.
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.
- Fabricated: Case Law | Approximately 24 unattributable or outright fabricated quotations in the opening brief that could not be traced to the cited opinions.
- Misrepresented: Case Law | At least seven cases in the brief were mislabeled as Seventh Circuit precedent when they were opinions from other circuits or otherwise unrelated.
- Misrepresented: Exhibits & Submissions | False factual assertions about the record — e.g., claiming 'credited testimony' that petitioner’s U.S. citizen children were 'deeply integrated into local schools' though all children are over 25 and out of school.
Questions this record answers
- What happened in Heriberto Perez-Castillo v. Todd W. Blanche?
- The court imposed a $5,000 monetary sanction on attorney Abdullah Salah under Federal Rule of Appellate Procedure 46(c) for failing to verify AI-generated content in his filings. The court also admonished the assisting attorney, Farah Chalisa, and referred both attorneys to the Illinois Attorney Registration and Disciplinary Commission for further investigation into potential ethical and professional conduct violations.
- Why does Heriberto Perez-Castillo v. Todd W. Blanche matter for legal AI risk?
- This case illustrates the severe consequences for lead counsel who fail to verify AI-assisted filings. It highlights that outsourcing research to non-appearing counsel does not absolve the signing attorney of the duty to ensure the accuracy of all citations and factual assertions.
- What does the public record establish about Heriberto Perez-Castillo v. Todd W. Blanche?
- 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 Heriberto Perez-Castillo v. Todd W. Blanche 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.