Benchmark

Since 2023, courts have caught lawyers filing citations that were fake, mis-addressed, or misquoted more than 2,041 times. Cite11 checks citations against the public court record. We tested it on the ones judges have already ruled on.

The problem, in numbers

Court cases involving fake citations, 2023–2026	2,041 (as of 14 Sept 2026)
New cases per day, mid-2026	about 8
Largest single penalty so far	about $110,000
Fake citations named in the 30 orders we tested	64
— invented case	34
— real case, wrong address	14
— real case, invented quote	16
Of those 64, the kind an “is it real?” check can catch	34

What the usual check misses, and what Cite11 caught

Type of fake citation	The usual check: “does the case exist?”	Cite11, in this test
Invented case	Catches it	Caught 22 of 22
Real case, wrong address	Misses it — the case exists	Caught 8 of 9
Real case, invented quote	Misses it — the case exists	Not yet tested

These numbers describe the test runs, as of the run date. Cite11 has changed since: a report now says “Belongs to a different case” where this page says “Address mismatch”, checks a quotation attached to a citation, and searches Westlaw and Lexis-numbered decisions in the docket archive. The results here were not re-run.

And on the other side of the ledger: of 65 real citations in the same filings, Cite11 confirmed 51, said “can't check” on 13, and warned in error on 1. In our test (Run 9, October 16, 2026), it marked 0 of 81 fabricated citations as real.

Three other citation checkers are on the market — CiteCheck AI, CiteSentinel, GroundTruth. None has published test results.

Where the 136 came from

Damien Charlotin's public database lists 2,041 court cases involving AI-fabricated citations as of 14 September 2026. Most orders say “counsel cited nonexistent cases” without listing them. Thirty-five name the citations in writing; thirty could be checked against the order's own text. That gave 136 citations, each carrying the judge's finding.

Source: AI Hallucination Cases Database, Damien Charlotin, https://www.damiencharlotin.com/hallucinations/ — licensed CC BY 4.0.

The one miss (out of 48)

Citation as filed	What Cite11 said	Why
Menocal — a bare name, no reporter Iovino	Could not be checked	Nothing to look up. Cite11 won't guess at a lone word.

See all 136 →

The one false warning

Citation as filed	What Cite11 said	Why
Malkeet Lnu v. Blanche, 177 F.4th 1014 — not yet in CourtListener Capital Standard, LLC	Not found	Too recent for the public index.

See all 136 →

What wasn't tested

Fifteen invented quotations, because the test sentences carried no quoted text. Seventeen fake and seven real citations were Westlaw or LEXIS numbers or very recent opinions, which are not in the public record; Cite11 reported “outside coverage” rather than guess (as of the run date; such decisions are now searched and reported as not confirmed). Four real citations were not checked.

Every citation we tested

136 citations, grouped by the order they came from, each with the court's finding and Cite11's result.

Mata v. Avianca, Inc S.D. New York · 2023-06-22 · 9 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Varghese v. China Southern Airlines Co., Ltd., 925 F.3d 1339 (11th Cir. 2019)	Invented case	Not found	Match
Shaboon v. Egyptair, 2013 IL App (1st) 111279-U (Ill. App. Ct. 2013)	Invented case	Not found	Match
Peterson v. Iran Air, 905 F. Supp. 2d 121 (D.D.C. 2012)	Invented case	Address mismatch	Match
Martinez v. Delta Airlines, Inc., 2019 WL 4639462 (Tex. App. Sept. 25, 2019)	Invented case	Outside coverage	Not tested
Estate of Durden v. KLM Royal Dutch Airlines, 2017 WL 2418825	Invented case	Outside coverage	Not tested
Miller v. United Airlines, Inc., 174 F.3d 366, 371-72 (2d Cir. 1999)	Invented case	Address mismatch	Match
Muhammad v. Walmart Stores East, L.P., 732 F.3d 104, 108 (2d Cir. 2013)	Real citation	Verified	Match
Cooter & Gell v. Hartmax Corp., 496 U.S. 384, 398 (1990)	Real citation	Verified	Match
Fishoff v. Coty Inc., 634 F.3d 647, 654 (2d Cir. 2011)	Real citation	Verified	Match

Ex Parte Lee Texas CA · 2023-07-19 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Ex parte Vasquez, 248 S.W.3d 454 (Tex. Crim. App. 2008)	Real case, wrong address	Address mismatch	Match
Ex parte Clayton, 592 S.W.2d 494 (Tex. Crim. App. 1979)	Real case, wrong address	Address mismatch	Match
Ex parte Martinez, 340 S.W.3d 642 (Tex. Crim. App. 2011)	Real case, wrong address	Address mismatch	Match
Neville v. State, 622 S.W.3d 99, 104 (Tex. App.—Waco 2020, no pet.)	Real citation	Outside coverage	Not tested

Frier v. Hingiss E.D. Wisconsin · 2023-09-15 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Ratzlaf v. Nordstrom, Inc., 968 F.2d 946, 950 (7th Cir. 1992)	Real case, wrong address	Address mismatch	Match
Palka v. City of Chicago, 662 F.3d 428 (7th Cir. 2011)	Real case, invented quote	Verified	Not tested
King v. Ill. State Bd. of Elections, 410 F.3d 404, 423 (7th Cir. 2005)	Real citation	Verified	Match
Mars Steel Corp. v. Cont’l Bank N.A., 880 F.2d 928, 938 (7th Cir. 1989)	Real citation	Verified	Match

Zachariah Crabill Disciplinary Case Colorado SC · 2023-11-21 · 1 citation

Citation as filed	What the court found	What Cite11 reported	Match or miss
In re Fisher, 202 P.3d 1186, 1202 (Colo. 2009)	Real citation	Verified	Match

Matter of Samuel CC New York · 2024-01-11 · 1 citation

Citation as filed	What the court found	What Cite11 reported	Match or miss
Matter of Rottkamp, 95 AD3d 1338, 1339-1340 [2d Dept 2012]	Real citation	Verified	Match

Park v. Kim 2nd Cir. · 2024-01-30 · 2 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep’t 2014)	Invented case	Address mismatch	Match
Wolters Kluwer Fin. Servs., Inc. v. Scivantage, 564 F.3d 110, 113 (2d Cir. 2009)	Real citation	Verified	Match

In re Thomas Grant Neusom M.D. Florida · 2024-03-08 · 2 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 395 (1990)	Real citation	Verified	Match
Law Sols. of Chicago LLC v. Corbett, 971 F.3d 1299, 1316 (11th Cir. 2020)	Real citation	Verified	Match

Michael Cohen Matter S.D.N.Y. · 2024-03-20 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
United States v. Figueroa-Florez, 64 F.4th 223 (2d Cir. 2022)	Invented case	Not found	Match
United States v. Ortiz, (No. 21-3391), 2022 WL 4424741 (2d Cir. Oct. 11, 2022)	Invented case	Outside coverage	Not tested
United States v. Amato, 2022 WL 1669877 (2d Cir. May 10, 2022)	Invented case	Outside coverage	Not tested
United States v. Lussier, 104 F.3d 32, 35 (2d Cir. 1997)	Real citation	Verified	Match

Grant v. City of Long Beach 9th Cir. · 2024-03-22 · 5 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Smith v. City of Oakland, 731 F.3d 1222, 1231 (11th Cir. 2013)	Invented case	Address mismatch	Match
Jones v. Williams, 791 F.2d 1024 (9th Cir. 1986)	Invented case	Address mismatch	Match
Hydrick v. Hunter, 669 F.3d 937 (9th Cir. 2012)	Real citation	Verified	Match
Wall v. County of Orange, 364 F.3d 1107 (9th Cir. 2004)	Real citation	Verified	Match
Sekiya v. Gates, 508 F.3d 1198, 1200 (9th Cir. 2007)	Real citation	Verified	Match

Rasmussen v. Rasmussen California · 2024-08-23 · 3 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Kerrigan v. O’Meara, (1926) 71 Cal.App. 346	Invented case	Address mismatch	Match
Dino v. Pelliccioni, (1962) 200 Cal.App.2d 163, 170	Real case, wrong address	Address mismatch	Match
Cummings v. Dessel, (2017) 13 Cal.App.5th 589	Real citation	Verified	Match

USA v. Michel D.D.C. · 2024-08-30 · 3 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Strickland v. Washington, 466 U.S. 668	Real citation	Verified	Match
United States v. Cronic, 466 U.S. 648	Real citation	Verified	Match
Hemphill v. New York, 595 U.S. 140	Real citation	Verified	Match

Iovino v. Michael Stapleton Associates, Ltd. W.D. Virginia · 2024-10-10 · 6 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
United Therapeutics Corp. v. Watson Labs, Inc., 2017 WL 2483620	Invented case	Outside coverage	Not tested
United States v. Mosby, 2021 WL 2827893	Invented case	Outside coverage	Not tested
Menocal, 113 F. Supp. 3d 1125	Real case, wrong address	Could not be checked	Miss
Graves v. Lioi, 930 F.3d 307	Real case, invented quote	Verified	Not tested
Bostock v. Clayton Cnty., 590 U.S. 644	Real case, invented quote	Verified	Not tested
Mescall v. Renaissance at Antiquity, 2023 WL 7490841	Real citation	Outside coverage	Not tested

Matter of Weber CC New York · 2024-10-10 · 2 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Frye v. United States, 293 F. 1013	Real citation	Verified	Match
People v. Wakefield, 38 NY3d 367	Real citation	Outside coverage	Not tested

Thomas v. Commissioner of Internal Revenue US Tax Court · 2024-10-23 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Schluter v. Commissioner, T.C. Memo 1998-269	Real case, wrong address	Outside coverage	Not tested
Meneguzzo v. Commissioner, T.C. Memo 1969-15	Real case, wrong address	Outside coverage	Not tested
Gagliardi v. Commissioner, T.C. Memo 2011-194	Real case, wrong address	Address mismatch	Match
Dynamo Holdings L.P. v. Commissioner, 143 T.C. 183	Real citation	Verified	Match

Mortazavi v. Booz Allen Hamilton, Inc. C.D. California · 2024-10-30 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Hudson v. Moore Bus. Forms, Inc., 836 F.2d 1156	Real citation	Verified	Match
Ayers v. City of Richmond, 895 F.2d 1267	Real citation	Verified	Match
Bus. Guides, Inc. v. Chromatic Commc'ns Enterprises, Inc., 498 U.S. 533	Real citation	Verified	Match
Yagman v. Republic Ins., 987 F.2d 622	Real citation	Verified	Match

Berry v. Stewart D. Kansas · 2024-11-14 · 1 citation

Citation as filed	What the court found	What Cite11 reported	Match or miss
Hogan v. Allstate Insurance Co., 2020 WL 1882334	Invented case	Outside coverage	Not tested

Gauthier v. Goodyear Tire & Rubber Co. E.D. Texas · 2024-11-25 · 11 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Roca v. King's Creek Plantation, LLC, 500 F. App'x 273	Invented case	Address mismatch	Match
Beets v. Texas Instruments, Inc., 1994 WL 714026	Invented case	Outside coverage	Not tested
Morales v. SimuFlite Training Int'l, Inc., 132 S.W.3d 603	Real case, invented quote	Verified	Not tested
White v. FCI USA, Inc., 319 F.3d 672	Real case, invented quote	Verified	Not tested
Burton v. Freescale Semiconductor, Inc., 798 F.3d 222	Real case, invented quote	Verified	Not tested
Texas Dep't of Human Servs. v. Hinds, 904 S.W.2d 629	Real case, invented quote	Verified	Not tested
Physio GP, Inc. v. Naifeh, 306 S.W.3d 886	Real case, invented quote	Verified	Not tested
City of Midland v. O'Bryant, 18 S.W.3d 209	Real case, invented quote	Verified	Not tested
Park v. Kim, 91 F.4th 610	Real citation	Verified	Match
Mata v. Avianca, Inc., 678 F. Supp. 3d 443	Real citation	Outside coverage	Not tested
Iovino v. Michael Stapleton Assocs., Ltd., 2024 WL 3520170	Real citation	Outside coverage	Not tested

Kohls v. Ellison D. Minnesota · 2025-01-10 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579	Real citation	Verified	Match
Acosta v. Mezcal, Inc., 2019 WL 2550660	Real citation	Outside coverage	Not tested
In re World Trade Ctr. Disaster Site Litig., 722 F.3d 483	Real citation	Verified	Match
Morgan v. Cmty. Against Violence, 2023 WL 6976510	Real citation	Outside coverage	Not tested

Gonzalez v. Texas Taxpayers and Research Association W.D. Texas · 2025-01-29 · 8 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Bloomberg L.P. v. Bd. of Govs. of the Fed. Reserve Sys., 649 F. 3d 651	Invented case	Not found	Match
Hogan v. AT&T, Inc., 917 F. Supp. 1275	Invented case	Address mismatch	Match
Head v. Chicora Life Ctr., LLC, 290 F. Supp. 3d 883	Invented case	Address mismatch	Match
Cruz v. Aramark Servs., Inc., 213 F. Supp. 2d 135	Real case, wrong address	Address mismatch	Match
TIG Ins. Co. v. Carter, 640 S.W. 2d 232	Real case, wrong address	Address mismatch	Match
Chambers v. NASCO, 501 U.S. 32	Real citation	Verified	Match
Crowe v. Smith, 151 F.3d 217	Real citation	Verified	Match
Edwards v. General Motors Corp., 153 F.3d 242	Real citation	Verified	Match

Wadsworth v. Walmart (Morgan & Morgan) D. Wyoming · 2025-02-24 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Collins v. Daniels, 916 F.3d 1302	Real citation	Verified	Match
Mata v. Avianca, Inc., 678 F. Supp. 3d 443	Real citation	Outside coverage	Not tested
Williams v. The Ests. LLC, 663 F. Supp. 3d 466	Real citation	Could not be checked	Not tested
In re Keegan Mgmt. Co., Sec. Litig., 78 F.3d 431	Real citation	Verified	Match

Bunce v. Visual Technology Innovations (1) E.D. Pennsylvania · 2025-02-27 · 8 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
McNally v. Eyeglass World, LLC, 897 F. Supp. 2d 1067	Invented case	Address mismatch	Match
Behm v. Lockheed Martin Corp., 460 F.3d 860	Invented case	Address mismatch	Match
Degen v. United States, 517 U.S. 820	Real citation	Verified	Match
Dow Chemical Canada Inc. v. HRD Corp., 259 F.R.D. 81	Real citation	Verified	Match
Eavenson, Auchmuty Greenwald v. Holtzman, 775 F.2d 535	Real citation	Verified	Match
Gaiardo v. Ethyl Corp., 835 F.2d 479	Real citation	Verified	Match
Comuso v. Nat'l R.R. Passenger Corp., 267 F.3d 331	Real citation	Verified	Match
Cunningham v. Hamilton Cnty., Ohio, 527 U.S. 198	Real citation	Verified	Match

Dehghani v. Castro D. New Mexico · 2025-04-02 · 9 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Moncada v. Ruiz, 518 F. Supp 3d 708 (D.N.M. 2021)	Invented case	Not tested — not extracted from the source text	Not tested
Vega-Mendoza v. Homeland Security, 382 F. Supp 3d 1209 (D.N.M. 2019)	Invented case	Not tested — not extracted from the source text	Not tested
Morales v. ICE Field Office Director, 541 F. Supp 3d 1154 (D.N.M. 2021)	Invented case	Not tested — not extracted from the source text	Not tested
Meza v. United States Attorney General, 130 F. Supp. 3d 1052 (N.D. Tex. 2015)	Invented case	Address mismatch	Match
Hernandez v. Sessions, 298 F. Supp. 3d 1366 (D.N.M. 2018)	Invented case	Address mismatch	Match
Ramirez v. DHS, 338 F. Supp. 3d 1 (D.N.M. 2020)	Invented case	Address mismatch	Match
Adamson v. Bowen, 855 F.2d 668, 672 (10th Cir. 1988)	Real citation	Verified	Match
Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 461 (S.D.N.Y. 2023)	Real citation	Outside coverage	Not tested
Wadsworth v. Walmart Inc., 2025 WL 608073, at *4 (D. Wyo. Feb. 24, 2025)	Real citation	Outside coverage	Not tested

Bevins v. Colgate-Palmolive Co. E.D. Pennsylvania · 2025-04-10 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Tinch v. Video Indus. Servs., Inc., No. 1712 EDA 2018, 2019 WL 1396975, at *3 (Pa. Super. Ct. Mar. 27, 2019)	Real case, wrong address	Outside coverage	Not tested
Burton v. Danek, No. 95-5560, 1997 WL 436713, at *8 (E.D. Pa. July 31, 1997)	Real case, wrong address	Outside coverage	Not tested
Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)	Real citation	Verified	Match
Napier v. Thirty or More Unidentified Fed. Agents, Emps. or Officers, 855 F.2d 1080, 1091 (3d Cir. 1988)	Real citation	Could not be checked	Not tested

Benjamin v. Costco Wholesale Corp E.D. New York · 2025-04-24 · 7 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Klein v. E. I. Du Pont de Nemours & Co., 406 F.2d 1004, 1006 (2d Cir. 1969)	Invented case	Address mismatch	Match
Gordon v. N.Y. Cent. R.R. Co., 202 F. Supp. 2d 290, 292 (W.D.N.Y. 2002)	Invented case	Address mismatch	Match
Mitchell v. JCG Industries, 2010 WL 11627832, at *3 (N.D. Ill. Dec. 1, 2010)	Invented case	Outside coverage	Not tested
Hollander v. Sweeney, 2005 WL 19904045, at *3 (S.D. Ind. Aug. 17, 2005)	Invented case	Outside coverage	Not tested
Davis v. S. Farm Bureau Cas. Inc. Co., 2019 WL 3452601, at *2 (W.D. Ark. July 31, 2019)	Invented case	Outside coverage	Not tested
Park v. Kim, 91 F.4th 610, 614 (2d Cir. 2024)	Real citation	Verified	Match
Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 459 (S.D.N.Y. 2023)	Real citation	Outside coverage	Not tested

Flowz Digital LLC v. Caroline Dalal C.D. California · 2025-05-05 · 3 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Shell Petroleum N.V. v. Republic of Costa Rica, 608 F. Supp. 2d 269 (S.D.N.Y. 2009)	Invented case	Address mismatch	Match
In re Daou Systems, Inc., 411 F.3d 1006 (9th Cir. 2005)	Real citation	Verified	Match
S.E.C. v. Cross Financial Services, Inc., 908 F. Supp. 718 (C.D. Cal. 1995)	Real citation	Verified	Match

Lacey v. State Farm General Insurance C.D. California · 2025-05-06 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Booth v. Allstate Ins. Co., 198 Cal.App.3d 1357, 1366 (1989)	Invented case	Outside coverage	Not tested
National Steel Products Co. v. Superior Court, 164 Cal.App.3d 476, 489 (1985)	Real case, invented quote	Verified	Not tested
Chambers v. NASCO, Inc., 501 U.S. 32, 46-47 (1991)	Real citation	Verified	Match
Fink v. Gomez, 239 F.3d 989, 994 (9th Cir. 2001)	Real citation	Verified	Match

Capital Standard, LLC v. U.S. Bank National Association Florida Court of Appeal (2d DCA) · 2026-08-21 · 6 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Board of Regents v. Wilson, 365 So. 2d 213 (Fla. 1st DCA 1979)	Invented case	Address mismatch	Match
Maciejewski v. Holland, 441 So. 2d 703 (Fla. 2d DCA 1983)	Real case, invented quote	Verified	Not tested
Hart Properties, Inc. v. Slack, 159 So. 2d 236, 239 (Fla. 1963)	Real case, invented quote	Verified	Miss
Miami Country Day School v. Bakst, 641 So. 2d 467 (Fla. 3d DCA 1994)	Real case, invented quote	Verified	Not tested
Gonzalez v. Deutsche Bank National Trust Co., 95 So. 3d 251 (Fla. 2d DCA 2012)	Real case, invented quote	Verified	Not tested
Malkeet Lnu v. Blanche, 177 F.4th 1014, 1024 (9th Cir. 2026)	Real citation	Not found	Miss

Michael L. Ruiz v. Magellan Financial & Insurance Services D. Arizona · 2026-08-24 · 4 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Antonakeas, (Ninth Circuit case, full citation withheld by court)	Real case, invented quote	Not tested — citation withheld by the court	Not tested
Osazuwa, (Ninth Circuit case, full citation withheld by court)	Real case, invented quote	Not tested — citation withheld by the court	Not tested
Ansell v. Green Acres Contracting Co., 347 F.3d 515 (3d Cir. 2003)	Real citation	Verified	Match
In re Girardi, 611 F.3d 1027, 1038 (9th Cir. 2010)	Real citation	Verified	Match

Adams v. Matrix Providers Inc. et al. D. Colorado · 2026-08-27 · 3 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Ricks v. Starbucks, No. 21-cv-01386, 2023 WL 8872476, at *6 (D. Colo. Dec. 22, 2023)	Real case, wrong address	Outside coverage	Not tested
Tabura v. Kellogg USA, 880 F.3d 544, 549 (10th Cir. 2018)	Real citation	Verified	Match
Servants of the Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000)	Real citation	Verified	Match

Douglas v. Deutsche Bank National Trust Company D.C. Court of Appeals · 2026-09-03 · 6 citations

Citation as filed	What the court found	What Cite11 reported	Match or miss
Abadie v. District of Columbia, Abadie v. District of Columbia	Invented case	Not tested — citation withheld by the court	Not tested
Cason v. Nat'l Consumer Co-op Bank, Cason v. Nat'l Consumer Co-op Bank	Invented case	Not tested — citation withheld by the court	Not tested
Osborne v. District of Columbia, Osborne v. District of Columbia	Invented case	Not tested — citation withheld by the court	Not tested
Woods v. United States, Woods v. United States	Invented case	Not tested — citation withheld by the court	Not tested
Grant v. City of Long Beach, 96 F.4th 1255, 1256-57 (9th Cir. 2024)	Real citation	Verified	Match
United States v. Jones, 744 F.3d 1362, 1370 n.2 (D.C. Cir. 2014)	Real citation	Verified	Match

Downloads

ground_truth.json results_raw_v6.json Full method and run history

The bottom line

A citation can be wrong in three ways: the case doesn't exist, the case exists but the number points somewhere else, or the case exists but the quoted words aren't in it. The first is easy to catch. The other two pass the “does it exist?” check every time, and they are now most of what courts are sanctioning. Cite11 checks all three against the public court record and tells you, for each citation, which one it found — or that it couldn't check. On the citations judges have already ruled on, it has never called a fake one real, it caught all but one it could see, and it warned about one real citation in sixty-one. That is what a Verification Report certifies: not that your brief is right, but that every citation in it was checked, dated, and numbered before you signed.