Check Your Citation

A neat citation to the wrong case, the wrong page or a passage that says something else does more harm than a messy one, because it looks checked. So check first and format last. The checks run in order, because each assumes the one before: there is no point testing a pinpoint in the wrong case. The form chapters that follow (ch. 2 to ch. 7) take the checks as done.

In the diagram, callouts 1 to 5 sit on elements of the citation. Callout 6 spans all of it, because status has no element of its own, which makes it the easiest check to skip.

Williams is itself a record of skipped checks. The court found six of the nine cases in an opening brief cited for quotations that do not exist or for propositions no one could plausibly draw from them. It struck the brief, let the appellant file a new one, and ordered her lawyers to pay the other side’s fees. Williams v. Honl, 348 Or. App. 505, 510–13 (2026).

Rules first, four checks, form last

Scale the effort, but skip no check: a dispositive standard or a quotation behind the relief you ask for gets a full read and a history check; a background citation still gets identity and location.

The same authority can need a different form, a disclosure or a certificate depending on where the paper goes, because whoever receives it sets the rules within their scope. So write down three facts first: the recipient, the kind of document, and the date you will file or submit it. Test every instruction against them.

Work down the layers: the statutes and court rules that reach the document (Table C); the court’s own layer of local rules, clerk’s guidance and the assigned judge’s standing orders, AI orders included (9.8); and any manual those instructions name, in the edition they name, wherever this book differs. A court’s own opinions are models, not orders, unless a rule adopts them. Where nothing governs, use this book’s forms consistently.

Read each instruction’s scope first: who issued it, what it reaches, when it took effect, whether it names a manual, and whether it binds or only recommends (14.11). New York’s Law Reporting Bureau manual, for one, instructs opinion writers, not filers. When two instructions seem to collide, compare their scope; if that does not settle it, ask the clerk, the editor or your supervisor, keep the answer in writing, and never split the difference. Journals, offices and courses set their own rules (chapter 8, chapter 10, chapter 11); for a filed paper, see 9.1. Four real instructions, one per kind:

Each row restates an official instrument as we read it on the date in its record. Read the instrument itself before you rely on a row.

Spend your time where the risk is. A district court’s local rule about form cannot be enforced to cost a party a right over a nonwillful lapse (Fed. R. Civ. P. 83(a)(2); 13.10). A fabricated or unsupported citation gets no such grace: in any court it can draw sanctions, from a reprimand or fee award to a struck brief or dismissed appeal (1.10).

A rule that binds you in one court is only a habit in another. So each statement here about what binds a writer, or what writers usually do, carries one label for its weight.

One of each: REQUIREMENT 14.11 · CONVENTION 14.3 · HOUSE STYLE 14.13 · UNRESOLVED 14.6 · LEGAL STATUS 13.5 · PERMISSION and WEIGHT 14.10 · TREATMENT 14.8.

A REQUIREMENT or LEGAL STATUS panel’s detail line gives the jurisdiction, the instrument, its effective date and scope, and our check date. Counts are not rules: Table H shows how often courts write a form, which is usage, never a requirement, a permission or precedential force.

A citation is a label on an address. The label is the name, court and date; the address is the volume, reporter and page, or the court’s own number. If the two belong to different documents, your reader lands on the wrong case or on nothing. Take each field from the document itself: the name from the caption, the court that decided it, the date printed on it, the docket number, and the citation from the reporter page or the court’s “Cite as” line (14.1).

A real page is not a real case. The sanctions opinion in Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023), numbers its findings, and findings 28 and 29 trace the invented citations, including those inside one fabricated opinion: several led to real pages holding other cases, and one borrowed a real Supreme Court name. Two of the real cases the court found:

Gibbs v. Maxwell House, 738 F.2d 1153 (11th Cir. 1984).

Zicherman v. Korean Air Lines Co., 516 U.S. 217 (1996).

The first is printed at one invented citation’s address. The second is the case whose name was borrowed, a Warsaw Convention damages case that never discussed the bankruptcy stay. A tool that confirms a volume and page has confirmed nothing about the name.

Same name, different decisions. Volume, page, court and year have to come from the one decision you mean; mixing them cites a decision that does not exist (the first pair in 1.12). Delaware’s Disney litigation shows the same trap in state court (14.8).

Loper Bright Enters. v. Raimondo, 45 F.4th 359 (D.C. Cir. 2022).

Loper Bright Enters. v. Raimondo, 603 U.S. 369 (2024).

Writings and versions. Identity includes which writing you cite, since a majority and a dissent can share a page (14.9), and which version: slip opinion or bound volume, code or CFR edition, bill version (13.6, 17.2). For enacted law, read the official text (13.8).

Database records are leads. Dates drift: CourtListener files People v. Buffer under January 22, 2020, though the court numbered it 2019 IL 122327 (14.3). One citation can map to several records: on October 13, 2026, a citation database returned two CourtListener record numbers for Loper Bright, 603 U.S. 369, a single decision. A record number is an access number, not a citation.

When identity fails, stop. Never repair a citation by guessing a nearby volume or page. Find the real document, or drop the sentence it was meant to support.

The first page identifies the document; the pinpoint finds the passage. A reader who has to hunt for your words either gives up or stops trusting you. Courts notice: an Oregon court used a footnote to remind counsel that many citations in a brief lacked pinpoints.

In re Marriage of Lee, 350 Or. App. 854, 855 n.1 (2026) (nonprecedential memorandum opinion).

Other sources take the same care (chapter 4). Use the source’s own locator: the printed page, the court’s paragraph number, every subsection level, the slip or star page, or the record page in the court’s system (16.5). Never a PDF viewer’s page counter. In the preliminary print of Loper Bright, the passage below is on PDF page 45 of the file and on printed page 412.

Loper Bright Enters. v. Raimondo, 603 U.S. 369, 412 (2024).

Three tests catch most location errors. The pinpoint falls inside the case: in Fletcher, the Fifth Circuit’s own Id. to Mata points to page 151, before Mata even begins (14.12). Every subdivision level exists in the version cited: the statute below opens at (a), then (1). And a footnote pinpoint names the note, as in “855 n.1” above.

42 U.S.C. § 2000e-2(a)(1) (2024).

Pinpoints belong to one version. Star pages do not carry over to the reporter, slip pages do not carry over to the U.S. Reports, and code editions renumber. When you switch versions, find the passage again; never compute it. That is why this chapter still cites Fletcher by its slip pages: a reporter citation has since appeared, but we have not yet read its pages. Where the court numbers its paragraphs, pinpoint the paragraph: ¶ 41 below is on PDF page 10 of the court’s file (14.6).

People v. Buffer, 2019 IL 122327, ¶ 41.

An existence check cannot catch a support failure: the case is real, the words are not in it. The Fifth Circuit has observed that the problem now often appears as false quotations or statements of law attributed to real cases.

Fletcher v. Experian Info. Sols., Inc., No. 25-20086, slip op. at 3 (5th Cir. Feb. 18, 2026).

Write your sentence first. Then read the passage with the paragraph before and the paragraph after, the footnotes and the heading, and decide only then. If the passage does not carry the sentence, change the sentence, the signal or the source; never stretch the passage.

Quotations. Copy every word, capital and mark as the version you cite prints it, and mark every change (chapter 3). A true quotation still has limits. The page below also says that earlier holdings decided under Chevron keep their statutory stare decisis effect, so it supports “the Court overruled Chevron,” not “every decision that relied on Chevron fell” (14.8).

“Chevron is overruled.” Loper Bright Enters. v. Raimondo, 603 U.S. 369, 412 (2024).

Voice. Whose words are they: a majority’s holding, a plurality’s reasoning, a concurrence, a dissent, a syllabus (no part of the opinion), or the court restating a party’s argument? In Yates, the opinion announcing the judgment spoke for four Justices, so cite its reasoning as a plurality’s and call it a reading, not a holding. Never write “held” for a dissent, a plurality or an argument the court only described (14.9).

Yates v. United States, 574 U.S. 528, 536 (2015) (plurality opinion).

Read the next page. In Hopewell, page 7 notes that the city council never adopted the ordinance a blight declaration needed. Page 8 then says the city’s immunity does not depend on that compliance; it turns on whether the city was performing a governmental function. A writer who stops at page 7 cites the case for a holding it did not make.

City of Hopewell v. Shree Arihant Motel, Inc., No. 251193, slip op. at 7 (Va. July 16, 2026).

Id. at 8.

Signals, facts, intermediaries. A signal is a claim about support, so choose it after reading (chapter 2). Cite a fact to the document that proves it, not to a complaint or a brief (16.2). And read the original, not a description: opinions describing other cases can be wrong, as Fletcher’s pinpoint to Mata is.

A real, well-located, well-supported citation can still mislead if the authority no longer does that work. Status has parts, each with its own source. History in the same case (affirmed, reversed, vacated) goes into the citation (14.8). Treatment by later decisions (overruled, limited, questioned) is reported for the proposition you cite, when it is negative or your point depends on it. Enacted law may have been amended, repealed, renumbered, removed, set aside or held invalid; say so in words, never by changing the address (13.9, 15.4). Permission and weight decide whether you may cite it here and how much it counts (14.10). One change of each of the first three kinds:

Loper Bright Enters. v. Raimondo, 45 F.4th 359 (D.C. Cir. 2022), vacated, 603 U.S. 369 (2024).

1 U.S.C. § 7 (2018), amended by Respect for Marriage Act, Pub. L. No. 117-228, § 5, 136 Stat. 2305, 2306 (2022).

Codified is not the same as enforceable: the 2026 CFR still printed a rule that a court had set aside in 2024 (15.4).

Citators find later history and citing decisions; then read the citing passages. A flag speaks about a whole case or headnote, not your proposition, and a count of citing opinions is usage, not status.

Which date? The events decide which version of a statute or rule governs (13.6); the filing date decides whether it is still good law and whether the forum’s instructions have changed.

Here is the method run on one citation, start to finish, with the sources we opened and what each showed.

The Court overruled Chevron but said that earlier holdings decided under it keep their statutory stare decisis effect. Loper Bright Enters. v. Raimondo, 603 U.S. 369, 412 (2024).

No new rules here: each row says what the checks turn on for one family of sources, and where the book applies them.

Courts and codes: Table A, Table B; court rules: Table C; words: Table D; journals: Table E; history phrases: Table F; foreign and international: Table G; usage: Table H.

Generative tools write citations that look right. Courts have described how fabricated citations fail, whoever or whatever drafted them, and every failure is a skipped check. The cure is the same for every draft: open the source, read it, compare it, check its status. Seven more decisions join Mata, Fletcher and Williams here:

Park v. Kim, 91 F.4th 610 (2d Cir. 2024) (per curiam) (referring counsel to the court’s Grievance Panel).

Grant v. City of Long Beach, 96 F.4th 1255 (9th Cir. 2024) (striking the opening brief and dismissing the appeal).

Kruse v. Karlen, 692 S.W.3d 43 (Mo. Ct. App. 2024) (dismissing the appeal and awarding $10,000 in damages for a frivolous appeal).

Shahid v. Esaam, 918 S.E.2d 198 (Ga. Ct. App. 2025) (vacating the trial court’s order and penalizing the appellee’s lawyer).

State v. Sandoval, No. S-1-SC-40845, ¶¶ 11–18 (N.M. Sept. 9, 2026) (per curiam) (nonprecedential order) (holding counsel in contempt and striking all briefing).

Shannon v. Shannon, 322 Neb. 451, 455–57 (2026) (striking a self-represented party’s brief).

U.S. Bank Tr. Nat’l Ass’n v. Thomas, No. CAAP-24-0000837, slip op. at 2 n.2 (Haw. Ct. App. Oct. 8, 2026) (summary disposition order).

Slip pages are each court’s own; we have not read the reporter pages of Grant, Kruse and Shahid. Grant does not say how its fabrications arose. Orders: above and 14.12 (Thomas found Rule 11 violations; its order imposed no sanction).

Oregon’s Court of Appeals has defined the term: fabricated authority is a citation to nothing, a quotation not in the source, a proposition the source does not reasonably support, or record facts with no basis; every row above is one of the four (14.12).

How an invented citation gives itself away. Each sign is a check, drawn from the decisions above.

• You cannot open it anywhere but in the tool that produced it, or the page you open holds another case (Mata, findings 28–29).
• The quoted words are not there. Search the opinion for them and for your key terms.
• The case is real but about something else: a civil-commitment class action and a dentist’s arrest, both offered as child-removal cases (Grant, slip op. at 4–5); a physician’s license suspension offered for a standard of review (Kruse, slip op. at 6).
• The pinpoint is impossible (1.5), or the facts are not in the record you can open (Sandoval, ¶ 4).

Represented or not, the duty is the same. The Nebraska Supreme Court said so, struck a self-represented father’s brief, and warned that later cases may be dismissed; it had already dismissed an appeal over a lawyer’s fabricated citations and referred the lawyer for discipline. Shannon, 322 Neb. at 455–57. The appellant in Kruse had paid an online “consultant” to write his brief, and his apology did not save the appeal. Kruse, slip op. at 8, 10.

When you find one. In your own draft, take it out and find real authority or drop the sentence. In a paper already filed, correct the record promptly and say exactly what was wrong; late candor does not undo the filing. Fletcher’s sanction rested in part on counsel’s not being forthcoming (slip op. at 2), and in Grant counsel did not acknowledge the fabrications even when asked at argument (slip op. at 6). In the other side’s paper, check its key citations and say what you found: the Thomas court found it concerning that the answering brief flagged none of the problems (slip op. at 2 n.2).

A checker is not the check. A lookup that says a citation exists has confirmed an address. Never ask the tool that produced a citation whether it is real: in Mata the lawyer did, and the chatbot answered that its cases were real and could be found on Westlaw and LexisNexis (finding 45). The Williams court warned that established legal publishers’ tools can fail the same way, and that drafting with a generative tool and then merely cite-checking is not competent practice. Williams, 348 Or. App. at 510 n.2, 513.

Rules now make you vouch for the result. None changes citation form. Each makes a signer, or whoever used AI, vouch for part of what the four checks test, so running all four covers what each asks; read each one’s exact words (9.8). Florida makes every signer represent that the legal authorities cited exist and are accurately cited; Connecticut makes anyone who used generative AI on a Superior Court filing verify the citations, authorities and evidence it produced; Indiana makes an attorney’s signature certify that cited authority is authentic. Other courts and judges want a disclosure or a certificate, and Texas and the Tenth Circuit had proposals pending on October 13, 2026. Disclosure never replaces verification. Citing AI output as a source: 20.8.

Drafts move: an Id. now points at the wrong case, a page break makes the table of authorities lie, a slip opinion gets its reporter page. Work substance first: identity failures, then support and quotations against the final sentences, then status and versions on the filing date, then locators, then form and short forms, then the forum’s format rules, and last the exported file itself, read at every page break and table. Never spend the last hour on commas around a holding no one has read.

Tables of authorities. Build the table from the final file, one entry and one spelling per authority, and check it both ways: every authority in the text is in the table, and every listed page holds it (9.2).

Cross-checks that late edits break. Short forms still point to the right antecedent (chapter 5); record cites match the final record (chapter 16); links resolve; quotations get one last comparison; blank page numbers (___) are filled where the reporter now gives one. On October 14, 2026, the Supreme Court’s table still gave this decision no page:

Write the audit down: file, checker, date, checks, repairs. Filing-day steps: 9.13.

One failure of each check. Form errors: 14.14 and each source chapter.