[Petitioner name redacted] v. United States Citizenship and Immigration Services
U.S. District Court, District of Oregon · D. Or. · Oregon bar guidance
Conduct
Here the court states that two filings by USCIS's counsel in a naturalization case contained hallucinated case citations.
Consequence
No sanction; the court allowed USCIS to file amended versions, then granted the petitioner's naturalization application on the merits.
Lesson
Here a government agency's filings drew a footnote about hallucinated citations in findings of fact and conclusions of law it lost on the merits.
Verified September 30, 2026
- Citation
- [Petitioner name redacted] v. U.S. Citizenship & Immigr. Servs., No. 3:24-cv-02135-SB, Redacted Findings of Fact and Conclusions of Law (D. Or. May 19, 2026) (Beckerman, M.J.), ECF No. 55 (filed June 9, 2026)
- Decided
- May 19, 2026
Summary
A naturalization applicant petitioned under INA section 310(c), 8 U.S.C. 1421(c), for de novo review of the denial of his Form N-400 by United States Citizenship and Immigration Services. The court held a bench trial on March 20, 2026. In its findings of fact and conclusions of law, Magistrate Judge Stacie F. Beckerman noted in a footnote that "USCIS's counsel submitted two court filings that contained hallucinated case citations," identifying them as the defendants' suggested findings of fact and conclusions of law (ECF No. 34) and the respondent's response to the petitioner's objections (ECF No. 36). The footnote does not identify the citations, name the attorney, or say how the citations came to be in the filings. The public version of the order is redacted: the petitioner's name, his country of origin and other identifying details are blacked out throughout, including in the caption, which prints no name for the petitioner.
- AI tool:
- Unidentified (the court states that two filings by USCIS's counsel "contained hallucinated case citations"; it does not say how they were produced or name a tool)
- Amount or terms:
- None; the court allowed USCIS to file amended versions of the two filings
How did the court address the AI-related conduct?
The footnote records that "[t]he Court allowed USCIS to file amended versions of those documents," which it cites as ECF Nos. 40 and 41. The order imposes no sanction and makes no further finding about the citations. On the merits, the court ruled against USCIS: it concluded that the petitioner met the statutory requirements for naturalization under INA sections 316 and 318, granted his application, ordered USCIS to naturalize him, arrange for him to take the oath of allegiance and issue a certificate of naturalization, and reserved jurisdiction to decide whether he is entitled to attorney's fees and costs under the Equal Access to Justice Act. The order is dated May 19, 2026; the redacted version was filed on June 9, 2026 as ECF No. 55.
Why does [Petitioner name redacted] v. United States Citizenship and Immigration Services matter for law firms using AI?
The court’s treatment of the citation problem is confined to one footnote in a sixteen-page decision on a naturalization petition. After a bench trial, Magistrate Judge Beckerman listed the materials she considered, including “the oral argument and written submissions of counsel,” and attached a footnote stating that “USCIS’s counsel submitted two court filings that contained hallucinated case citations.” The footnote identifies the two filings by docket number (the suggested findings of fact and conclusions of law at ECF No. 34 and the response to the petitioner’s objections at ECF No. 36) and records that “[t]he Court allowed USCIS to file amended versions of those documents” (ECF Nos. 40 and 41).
The order goes no further. It does not say which citations were affected, whether the court or the petitioner found them, how they were produced, or who drafted the filings, and it neither imposes nor discusses a sanction. The word “hallucinated” is the court’s own; the order does not otherwise mention artificial intelligence. The decision then ruled for the petitioner, granting naturalization and reserving jurisdiction over a fee application under the Equal Access to Justice Act.
The entry is included because the court itself states, in its findings of fact and conclusions of law, that filings before it contained hallucinated case citations. The public copy is heavily redacted, and the caption prints no name for the petitioner; this entry uses a bracketed placeholder rather than any name.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Verify citations in proposed findings of fact and conclusions of law as closely as in a brief. Here the court's footnote identifies two filings by USCIS's counsel that contained hallucinated case citations.
- Document how corrected filings are handled when a court permits amendment. Here the court allowed amended versions (ECF Nos. 40 and 41) and recorded the original problem in a footnote to its findings and conclusions.
- Consider that a court may note hallucinated citations in the decision itself even when it imposes no sanction and does not name the attorney.
Sources
Primary sources
- The order does not attribute the 'hallucinated case citations' to generative AI or any tool, and does not identify which citations were affected; the AI attribution in the Charlotin tracker ('Implied') is an inference from the court's word 'hallucinated'.
- The order does not name USCIS's counsel or say whether counsel was government or outside counsel, and it does not describe how or when the court allowed the amended filings (the underlying docket orders were not reviewed).