Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi
10th Cir. CA · Feb 13, 2026
What happened in this matter?
The Tenth Circuit Court of Appeals issued a formal warning to counsel for relying on a fabricated case citation in his appellate brief. The court concluded the citation was likely generated by AI and warned counsel of the professional responsibility to ensure all cited authorities are real and accurately represent the propositions for which they are cited.
- Why the court cared
- Fabricated: Case Law | Counsel repeatedly cited and quoted a non-existent Tenth Circuit decision captioned 'Rodriguez-Romero v. Garland, 60 F.4th 1283 (10th Cir. 2023)'; the court found no such opinion and that the pincites pointed to unrelated cases (Wesley and Diaz-Menera), concluding the citation appears fabricated, likely generated by AI.
- Why it matters now
- Pull every circuit-court cite directly from Westlaw or the court's PACER docket; AI will invent plausible F.4th numbers.
Why this matter is tracked
In an immigration appeal, the Tenth Circuit Court of Appeals denied the petitioners' request for review of a removal order. During the proceedings, the court identified that counsel repeatedly cited and quoted a non-existent Tenth Circuit decision, 'Rodriguez-Romero v. Garland, 60 F.4th 1283 (10th Cir. 2023).' The court determined that the case was fabricated, likely due to counsel's use of generative AI without adequate verification. The court noted that the pincites provided by counsel actually pointed to unrelated criminal cases. While the court emphasized that such conduct is sanctionable, it declined to impose formal sanctions in this instance, opting instead to issue a formal warning to counsel regarding the duty to verify all legal citations.
Pull every circuit-court cite directly from Westlaw or the court's PACER docket; AI will invent plausible F.4th numbers.
Record details
What the record establishes about AI use
The court attributed the fabrication to the use of a generative AI tool.
Appellate review of a Board of Immigration Appeals (BIA) decision upholding an immigration judge's denial of asylum and withholding of removal.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Counsel repeatedly cited and quoted a non-existent Tenth Circuit decision captioned 'Rodriguez-Romero v. Garland, 60 F.4th 1283 (10th Cir. 2023)'; the court found no such opinion and that the pincites pointed to unrelated cases (Wesley and Diaz-Menera), concluding the citation appears fabricated, likely generated by AI.
Questions this record answers
- What happened in Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi?
- The Tenth Circuit Court of Appeals issued a formal warning to counsel for relying on a fabricated case citation in his appellate brief. The court concluded the citation was likely generated by AI and warned counsel of the professional responsibility to ensure all cited authorities are real and accurately represent the propositions for which they are cited.
- Why does Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi matter for legal AI risk?
- Pull every circuit-court cite directly from Westlaw or the court's PACER docket; AI will invent plausible F.4th numbers.
- What does the public record establish about Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi?
- 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.
- Which source supports this Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi 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.