Fabricated citations have become a real problem in courts across the country. As of this month, the public database tracking AI-hallucination incidents in court filings has climbed past 1,700 cases worldwide—up from a few hundred as recently as six months ago. The curve is steep, and it’s not slowing down.
The Tenth Circuit underscored the point just yesterday in Lichfield v. Kubler (2026 WL 2146985). Although the court didn’t sanction the offending lawyer, it didn’t let the moment pass quietly, either. The opening brief had cited an authority that doesn’t exist and mischaracterized two real cases beyond what their text supports. The court’s message to the profession was plain: lawyers who use generative AI must bring their own judgment to the table, since the tool “is no longer a novel tool,” and its use demands what the court called “actual intelligence in its execution.”
That line should sting a little, in a useful way. When courts are actively hunting for fabrications, every lawyer’s credibility is a little more fragile than it used to be—and the fix isn’t just “double-check that the case exists.” It’s a broader habit of accuracy, down to the smallest details of how you cite.
Which brings us to signals. Don’t let the panic over hallucinated cases make you forget the basics. Signals aren’t decoration. They carry real information about what your authority actually says. Use no signal when the source directly states your point, is the source of a quotation, or is named in your text. Use supporting signals (see, see also, accord, e.g.) when the source backs you up but doesn’t earn the “no signal” treatment—often because the support is inferential. The citations just listed are in order of increasing indirectness of support. Use comparative signals (cf.; compare … with …) for analogies or contrasts that only indirectly touch your point, and lean on parentheticals to explain the relationship. Use contradictory signals (contra, but see, but cf.) when the authority cuts against you, directly or by implication. And use see generally for background, not for the rule itself. If you’re stringing signals together in one citation sentence, the Bluebook wants them in order: supporting, then comparative, then contradictory, then background.
A hallucinated citation is the most dramatic failure of accuracy, but it’s not the only one. A see where you meant accord. A cf. doing the work of a direct citation. A quotation pulled slightly out of context and dropped in with no signal at all, implying a fit that isn’t really there. These are smaller sins than fabricating a case—but they’re sins of the same species: they misrepresent what your authority actually says.
Check the case. Check the quote. And check that the signal you’ve chosen is telling the truth about what you found.