Heriberto Perez-Castillo v. Todd W. Blanche
The case
Heriberto Perez-Castillo v. Todd W. Blanche, Acting Attorney General of the United States, 7th Cir., No. 25-1988, opinion filed June 1, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-153-perez-castillo-v-blanche.pdf`.
What happened
Counsel of record Abdullah Salah signed and submitted two briefs riddled with AI hallucinations, including two dozen fabricated quotations, seven cases wrongly identified as Seventh Circuit precedent, erroneous legal propositions, and factual assertions flatly contradicted by the record. Salah blamed Farah Chalisa, an attorney not entered on the case, who he said used ChatGPT only for "stylistic and grammatical review."
The rule and the sanction
Federal Rule of Appellate Procedure 46(c), the court's rules of professional conduct, and multiple Federal Rules of Appellate Procedure. Sanction: a $5,000 fine on Salah. The court declined to sanction Chalisa at this time but admonished her and referred the matter to the Attorney Registration and Disciplinary Commission of Illinois; both attorneys must file status reports in one year on any ARDC action.
How it could have been avoided
Counsel of record is responsible for every brief signed, even when a contractor drafts it. Read outsourced briefs against the authorities before signing; blaming the drafter does not shift Rule 46 liability.
---