Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi
10th Cir. CA · Feb 13, 2026
- Jurisdiction
- federal
- Court
- 10th Cir. CA
- Record ID
- martha-liliana-picon-diaz-et-al-v-pamela-j-bondi-2026-02-13
- Observed outcome
- The court denied the petition for review and issued a formal warning to counsel regarding the use of fabricated legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Pull every circuit-court cite directly from Westlaw or the court's PACER docket; AI will invent plausible F.4th numbers.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Immigration
- Appellate
- Warning
- AI attribution
- Implied
- Recorded tool
- Generative artificial intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a Board of Immigration Appeals (BIA) decision upholding an immigration judge's denial of asylum and withholding 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 attributed the fabrication to the use of a generative AI tool.
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.
- Do not treat a paid legal-research product as a substitute for source verification.