Garibay-Robledo v. Noem
U.S. District Court, Northern District of Texas, Abilene Division · N.D. Tex. · Texas bar guidance
Verified April 26, 2026
- Citation
- Garibay-Robledo v. Noem, No. 1:25-CV-177-H, 2026 WL 81679 (N.D. Tex. Jan. 9, 2026)
- Decided
- January 9, 2026
Summary
Petitioner's counsel John M. Bray filed a habeas petition citing a non-existent Fifth Circuit case as binding precedent for an immigration bond hearing. After Judge James Wesley Hendrix repeatedly flagged the fabricated citation, Bray admitted in a sworn declaration that the cited authority had been obtained from a Facebook comment. Bray filed a corrected petition that reasserted the same legal claim with no supporting citation. The reply brief also contained a fabricated quotation that required correction.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. Judge Hendrix denied the corrected habeas petition on the merits and issued a Rule 11 warning, reminding Bray of his certification obligations and citing Willy v. Coastal Corp. and Gauthier v. Goodyear Tire & Rubber Co. for the proposition that citations to nonexistent rules of law are sanctionable.
Why does Garibay-Robledo v. Noem matter for law firms using AI?
Garibay-Robledo is notable for the cite-source admission: counsel told the court the fabricated Fifth Circuit authority came from a Facebook comment, not a generative AI tool. The order does not name an AI product, and the court treats the conduct as a Rule 11 problem regardless of provenance. For managing partners, the case underscores that the verification duty attaches to any unvetted citation, social-media tips and chatbot output alike, and that a corrected filing which simply repeats an unsupported claim does not cure the underlying Rule 11 exposure.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.