Heriberto Perez-Castillo v. TODD W. BLANCHE, Acting Attorney General of the United States

In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 25-1988
HERIBERTO P EREZ-C ASTILLO,
Petitioner,
v.
T ODD W. B LANCHE, Acting Attorney General of the United
States,
Respondent.
____________________
Petition for Review of an Order
of the Board of Immigration Appeals.
No. A206-788-938
____________________
A RGUED FEBRUARY 17, 2026 — D ECIDED J UNE 1, 2026
____________________
Before BRENNAN, Chief Judge, and R IPPLE and T AIBLESON,
Circuit Judges.
BRENNAN, Chief Judge. Heriberto Perez-Castillo petitioned
this court to review a final order of removal from this country.
At the same time, his immigration case raises a pressing con-
cern facing the legal profession today: the use of artificial in-
telligence (“AI”) in litigation. Perez-Castillo’s opening brief
was riddled with AI hallucinations. These included two

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2 No. 25-1988
dozen fabricated quotations, seven cases wrongly identified
as precedent from this circuit, erroneous legal propositions,
and assertions of fact flatly contradicted by the record.
Counsel for Perez-Castillo, Abdullah Salah, blamed these
errors on another attorney with whom he had contracted to
write the brief. That attorney, Farah Chalisa, did not enter an
appearance in this case. In Salah’s telling, Chalisa used
ChatGPT for “stylistic and grammatical review” that resulted
in the hallucinations. To better understand what happened,
we issued an order to show cause why both attorneys should
not be sanctioned for their conduct. Both Salah and Chalisa
responded, offering their respective sides of the story.
On the merits, we deny Perez-Castillo’s petition for review
because it cannot succeed as a matter of law. As for attorney
Salah, we impose a fine of $5,000 for violating this court’s
rules of professional conduct and multiple Federal Rules of
Appellate Procedure. Though we decline to sanction attorney
Chalisa at this time, we refer this matter to the Attorney Reg-
istration and Disciplinary Commission of Illinois for any fur-
ther action it deems appropriate.
I
A
Heriberto Perez-Castillo is a citizen of Mexico who has
lived illegally in the United States for most of his life. He first
arrived as an infant, but in 2002 he re-entered the country
without inspection after briefly leaving. Perez-Castillo has
had several run-ins with law enforcement throughout his
time in the United States, including multiple arrests for drug
crimes and domestic violence.

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No. 25-1988 3
One criminal incident matters here. Late one night in 2012,
Perez-Castillo showed up “highly intoxicated” to his mother’s
house. They got into an argument. According to the police re-
port, Perez-Castillo then pushed his mother to the floor,
kicked her eye, and hit her on the head with “a closed beer he
held in his hand.” When his brother and two sisters tried to
break up the fight, he punched each of them in the face, giving
them bloody noses.
Perez-Castillo was convicted of battery under Illinois law.
See 720 ILCS 5/12-3(a)(1). The court sentenced him to eighteen
months of supervision, some of which he served in prison af-
ter he violated the terms of his supervision.
When the Department of Homeland Security initiated
removal proceedings against Perez-Castillo, his conviction
became a sticking point. Perez-Castillo conceded his remova-
bility but applied for cancellation of removal under 8 U.S.C.
§ 1229b(b). The immigration judge denied his application,
concluding that Perez-Castillo was ineligible for this form of
discretionary relief. Federal immigration law bars anyone
convicted of a “crime of domestic violence” from receiving
this remedy. Id. at (b)(1)(C) (cross-referencing id.
§ 1227(a)(2)(E)(i)). Because the victims of his battery convic-
tion were his mother and siblings, the immigration judge con-
cluded he was categorically ineligible for cancellation of re-
moval.
Independent of his prior conviction, the immigration
judge gave another reason for rejecting Perez-Castillo’s appli-
cation. By statute, an applicant is eligible for cancellation of
removal only if his removal “would result in exceptional and
extremely unusual hardship to the alien’s spouse.” Id.
§ 1229b(b)(1)(D). Perez-Castillo’s wife, a United States citizen,

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4 No. 25-1988
did have some health problems and depended on her hus-
band to provide for her needs. But she also lived near her fa-
ther and four adult children from a previous marriage, who
could help ease the financial and emotional strain. The immi-
gration judge concluded that these hardships, though real,
were not “substantially beyond the hardship typically experi-
enced when a family member is removed from the United
States.”
The Board of Immigration Appeals affirmed. It agreed in
full with the immigration judge’s conclusion that the battery
conviction was a “crime of domestic violence.” And the Board
noted that Perez-Castillo waived his challenge to the immi-
gration judge’s hardship analysis by failing to raise it before
the Board. Perez-Castillo timely petitioned this court for re-
view. 8 U.S.C. §§ 1252(a)(1), (b)(1).
B
Cancellation of removal is a discretionary remedy, so we
review the decisions of the immigration judge and the Board
of Immigration Appeals with a high degree of deference. San-
tos Mendoza v. Bondi, 151 F.4th 900, 903, 905 (7th Cir. 2025). We
lack jurisdiction to revisit the facts found by the agency. 8
U.S.C. § 1252(a)(2)(B); see Patel v. Garland, 596 U.S 328, 347
(2022). And though we have jurisdiction to consider mixed
questions of law and fact, 8 U.S.C. § 1252(a)(2)(D), we apply a
“deferential standard of review.” Wilkinson v. Garland, 601
U.S. 209, 222 (2024).
The unanimous Supreme Court recently explained the
standard of review we apply to all final orders of removal re-
viewable under § 1252(a). Urias-Orellana v. Bondi, 146 S. Ct.
845, 851 (2026). Mixed questions of law and fact—like the

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No. 25-1988 5
question of exceptional and extremely unusual hardship in
this case—are reviewed for “substantial evidence.” Id. Appel-
late courts reverse under that test only “if, in reviewing the
record as a whole, any reasonable adjudicator would be com-
pelled to conclude to the contrary.” Id. at 849; see also 8 U.S.C.
§ 1252(b)(4)(B).1 Pure questions of law, by contrast, are re-
viewed de novo. Urias-Orellana, 146 S. Ct. at 849 n.1. But most
questions in the immigration context are mixed questions of
law and fact, so the immigration judge’s overall conclusions
merit significant deference. Wilkinson, 601 U.S. at 222.
Applying these principles, we must deny this petition for
review. Before anything else, Perez-Castillo waived any chal-
lenge to the immigration judge’s hardship determination in
front of the Board of Immigration Appeals.2 And he did not
challenge the Board’s waiver determination before this court.
Waiver alone requires us to deny his petition. See Munoz-Ri-
vera v. Garland, 81 F.4th 681, 687–88 (7th Cir. 2023). A
petitioner is eligible for cancellation of removal only if he af-
firmatively establishes that all four criteria in the statute are
satisfied, including the hardship prong. Santos Mendoza, 151
F.4th at 906. That burden was not satisfied here.
1 This court has observed that “circuit courts have engaged in a fairly
abstract debate about a precise formulation for the appropriate deferential
standard of review” after the Wilkinson decision. Santos Mendoza, 151 F.4th
at 905 (collecting cases). Though we did not choose a side in that dispute,
Urias-Orellana answers the question for us. The substantial evidence test
applies because § 1252’s jurisdictional provisions do “not speak to the
standard of review for removal orders.” Urias-Orellana, 146 S. Ct. at 854.
The only provision speaking to standard of review is § 1252(b)(4), so we
follow Urias-Orellana’s interpretation of that provision.
2 See Administrative Record at 3–4.

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6 No. 25-1988
Even if we did reach the hardship question, nothing in the
administrative record compels us to reverse the rulings of ei-
ther the immigration judge or the Board. The immigration
judge considered all the relevant factors, including the age,
health, and other circumstances of Perez-Castillo’s wife (his
qualifying relative). Yet, she determined that these
circumstances are not out of the ordinary. We agree with her
reasoning. Removal will always cause hardship for a spouse
or family member. The mitigating factors in this case, includ-
ing the ready availability of family support, indicate that Pe-
rez-Castillo’s wife faces no “exceptional and extremely
unusual hardship.” 8 U.S.C. § 1229b(b)(1)(D). At the least, the
immigration judge is due deference under the substantial ev-
idence test, and nothing in this record compels a contrary con-
clusion. Id. § 1252(b)(4)(B).
Finally, Perez-Castillo’s application fails because of his
battery conviction. Independent of the hardship analysis, a
petitioner is ineligible for cancellation of removal if he has
been convicted of a “crime of domestic violence.” 8 U.S.C.
§ 1229b(b)(1)(C) (cross-referencing id. § 1227(a)(2)(E)(i)).
There are two steps to determine whether an offense counts
as a “crime of domestic violence.” The first is whether the of-
fense is a “crime of violence” under 18 U.S.C. § 16. Caldera-
Torres v. Garland, 66 F.4th 651, 653 (7th Cir. 2023). The second
is whether the victim of that offense was a family member
listed in 8 U.S.C. § 1227(a)(2)(E)(i). Id.
Perez-Castillo’s conviction fits the bill. On the first prong,
this court has repeatedly held that a battery conviction under
720 ILCS 5/12-3(a)(1) categorically qualifies as a “crime of vi-
olence.” See, e.g., United States v. Shaffers, 22 F.4th 655, 666 (7th
Cir. 2022) (citing United States v. Vesey, 966 F.3d 694, 697 (7th

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No. 25-1988 7
Cir. 2020)). And an offender’s mother and siblings are “pro-
tected from that individual’s acts under the domestic or fam-
ily violence laws of” Illinois. 8 U.S.C. § 1227(a)(2)(E)(i); see 720
ILCS 5/12-3.2(a) (proscribing battery against “any family or
household member”), and id. at 5/12-0.1 (defining “family or
household members” to include “parents, … and other per-
sons related by blood”). Because Perez-Castillo does not con-
test that his mother and siblings were the victims of his 2012
battery conviction, he is ineligible for cancellation of removal.
For these reasons, the decisions of both the immigration
judge and the Board stand. We deny this petition for review.
II
That is not the end of this matter. As we reviewed the case,
we discovered several problems with the petitioner’s brief.
Roughly half of the cases cited in the brief either do not exist
or were falsely labeled as Seventh Circuit cases. Moreover,
nearly every quotation in the brief could not be traced to a real
opinion—hallmarks of AI hallucinations.3
Suspecting that AI was used to prepare the brief, we took
a series of steps to better understand how these errors came
about. For the benefit of other courts facing similar issues, we
detail these steps before turning to sanctions.
A
The first twelve pages of the petitioner’s opening brief ap-
peared ordinary, aside from a few errors.4 But the first several
3 Salah did not file a reply brief on behalf of Perez-Castillo.
4 The brief included incorrect dates and a record cite mismatched to
the sentence it supported. It also stated the Immigration Judge issued an
oral decision when she issued a written decision.

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8 No. 25-1988
pages of the standard of review and discussion sections in-
cluded quotes that could not be found in the cited opinions.
The last eleven pages of the brief contained the most seri-
ous errors. From pages 19 to 29, every quote appeared to be
an AI hallucination. And many of the “Seventh Circuit” cases
cited turned out to be mislabeled opinions from other circuits
that were unrelated to the issues in this case. One case does
not exist at all.5 All told, there were twenty-four unattributa-
ble or outright false quotes, along with at least seven misla-
beled or nonexistent cases.
As troubling were the false or unsupported claims about
the record recited in the brief. For one, it described “[c]redited
testimony” that Perez-Castillo’s “U.S. citizen children” would
face hardships with their education, because they were
“deeply integrated into local schools.” Yet all Perez-Castillo’s
children are over the age of twenty-five and out of school. For
another, it argued that the agency ignored “extensive docu-
mentation detailing pervasive economic instability, lack of ac-
cessible healthcare, and political insecurity in Petitioner’s
home country.” So, his wife and children would face the
choice of “relocating to a country where their safety, educa-
tion, and healthcare would be compromised” or remaining in
this country without his support. But the record contains no
evidence of political instability in Mexico, and Perez-Cas-
tillo’s wife testified that even if her husband was deported,
she planned to stay in the United States. Finally, in discussing
the hardship standard, the brief suggests the Board of
5 To avoid memorializing errors, we have chosen not to include any
of the false citations or quotes in this opinion. The original brief can be
found at docket entry 15 on the CM/ECF page for this case.

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No. 25-1988 9
Immigration Appeals disregarded the Immigration Judge’s
factual findings and “insert[ed] its own unsupported assump-
tions” into the record. In reality, the Board did not discuss any
of this evidence in its two-page opinion because it concluded
that Perez-Castillo waived his hardship challenge.
B
After discovering these issues, we ordered the petitioner
to respond and explain “whether any form of generative-arti-
ficial intelligence (AI) assistance was used in preparing the
petitioner’s brief.” We also reinstated oral argument, which
had previously been waived at the joint request of the parties.
And we instructed the parties to be prepared to discuss these
concerns in person. That order was issued three and a half
weeks before oral argument.
Two weeks later, Attorney Salah filed his response. He ad-
mitted AI was used in preparing the brief but attributed it to
another lawyer. Salah informed us that he had outsourced the
research and preparation of the brief to Farah Chalisa, a mem-
ber of the Illinois bar. In fact, Salah conceded that he “had no
input in the research and preparation of the brief and fully
believed that it was in compliance with all court rules, orders
and the Rules of Ethics.” Salah claimed that Chalisa told him
she used AI “for the limited purpose of stylistic and grammat-
ical review,” but she did not do a “final and complete line by
line verification of quotations and citations.”
Salah also informed us that he was waiting for corrections
from Chalisa so he could file a revised brief. He ultimately
filed that brief late the night before oral argument. Though the
new brief did replace the inaccurate citations with real cases,
it did not cure all deficiencies. The text of the new brief was

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10 No. 25-1988
substantially unchanged. In many places, it still made sweep-
ing, unsupported statements about our caselaw. And it did
not remedy the factual problems about Perez-Castillo’s family
and the agency proceedings.
C
At oral argument, we inquired about Salah’s response to
our order regarding AI use in petitioner’s brief.6 He reiterated
that Chalisa wrote the brief in full and that he played no part
in preparing it. “[H]er contention” remained that the errors
were the product of a grammar check run through ChatGPT.
In his words, the “citations were changed in a way that I don’t
understand.”
When questioned, Salah admitted he had not reviewed the
original brief for accuracy. Nor had he reviewed the edited
brief. And when asked about the factual misrepresentations
in the record, he struggled to answer basic questions about
the age of his client’s children.
In a particularly telling exchange, Salah defended his
choice not to review the briefs by pointing at Chalisa. He said,
“I assume when an attorney has put themselves out there as
an attorney that … writes briefs that they’re following the
rules. And I didn’t believe that it was on me to redo the brief
for someone who’s writing briefs as an attorney.” We re-
minded him that under the Federal Rules of Appellate Proce-
dure and this court’s standards of professional conduct, he
6 The audio recording of the oral argument for this case can be found
on the court’s website. The discussion of AI usage in the brief begins at
4:13 and resumes at 15:49.

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No. 25-1988 11
was responsible for any brief going out in his name. Salah re-
plied, “I understand.”
D
After oral argument, we issued an order to show cause di-
rected at both Salah and Chalisa. We noted that both briefs
might run afoul of several Federal Rules of Appellate Proce-
dure and that we were considering sanctions. In his response,
Salah again ascribed the errors to Chalisa, but he admitted he
should have reviewed the brief.
Chalisa’s response provided more details. Through
counsel, she admitted she “used ChatGPT to perform the
copyediting tasks necessary” to ensure the brief “was as
grammatically correct as possible,” as well as to confirm that
it was “structurally and stylistically appropriate.” Yet, she
averred she did not use ChatGPT or any other large language
AI model “to perform any legal research or to draft the peti-
tion itself.” She did, however, hint at using “any system in-
corporated into Lexis/Nexis” as part of her research process—
a portion of her response that is still unclear.
Chalisa submits that during this grammar check, ChatGPT
“hallucinate[d] facts not present in the record in this matter
and insert[ed] them into the draft petition.” She also says it
rendered her “correct case citations incorrect by changing cir-
cuit numbers, page numbers, and the like.” She asserts she “in
no way instructed or prompted ChatGPT to do any of that.
But that is what it did.”
Then, without further review, Chalisa sent the “grammar-
checked” brief to Salah, who filed it with this court. After Sa-
lah learned about the errors, he asked Chalisa to fix the brief.
She submits that she “understood Mr. Salah to be asking for

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12 No. 25-1988
her assistance with correcting case citations,” but she was
“not aware of the factual errors that remained in the petition.”
So, she removed the erroneous citations and “sent the cor-
rected petition back to Mr. Salah.”
Overall, Chalisa’s response is apologetic. Expressing her
regret for these mistakes, she accepts responsibility for not
checking the brief after using ChatGPT. And she assures us
this “will not happen again.” She also committed to attending
Illinois’s Minimum Continuing Legal Education course on the
risks, benefits, and ethical considerations of using AI. Noting
that she is a new attorney who has worked as a sole practi-
tioner since 2025, she asks us to discharge the order to show
cause without imposing sanctions.7
III
Not every case involving the misuse of AI merits sanc-
tions. This court chose not to sanction a pro se litigant who
included a few “non-existent quotations” in his appellate
brief. Jones v. Kankakee Cnty. Sheriff’s Dep’t, 164 F.4th 967, 969–
71 (7th Cir. 2026). So too where a member of this court’s bar
submitted a brief with similar errors in its standard of review
section, which were “presumably copied and pasted” from
another brief. Dec v. Mullin, 171 F.4th 940, 946–47 (7th Cir.
2026). Because that attorney did not misrepresent the facts or
substantive law, and given her acceptance of responsibility
and sincere apology, we merely admonished her. Id. at 947.
This case is categorically different. The petitioner’s brief
was replete with false quotations, erroneous statements of
law, and factual representations contradicted by the record.
7 Chalisa was admitted to the Illinois bar in January 2021.

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No. 25-1988 13
Further, the attorney who signed the brief admitted to violat-
ing this court’s rules of professional conduct but did not take
responsibility or apologize. The author of the brief has shown
contrition, yet she has not provided a fully satisfying expla-
nation for these errors. We address each attorney’s culpability
in turn.
A
Federal courts confronted with AI hallucinations in briefs
and motions have identified several sources of authority for
sanctions. Most district courts rely on Federal Rule of Civil
Procedure 11, 28 U.S.C. § 1927, and the court’s inherent au-
thority to sanction for bad faith conduct. See generally Zheng v.
Internet Corp. for Assigned Names and Nos., 813 F. Supp. 3d
1135, 1138–44 (C.D. Cal. 2025); Disability Rights Miss. v. Palmer
Home for Children, No. 1:24-cv-99-SA-DAS, 2025 WL 3691876
(N.D. Miss. 2025); Obi v. Cook County, No. 25-cv-3096, 2026 WL
1001481 (N.D. Ill. 2026). The courts of appeals, by contrast,
have invoked a few different sources for sanctioning attor-
neys. No unified approach prevails. See, e.g., Amarsingh v.
Frontier Airlines, Inc., No. 24-1391, 2026 WL 352016, at *5–8
(10th Cir. 2026) (electing to proceed under F ED. R. A PP. P. 38);
Fletcher v. Experian Info. Sols., Inc., 168 F.4th 231, 239–40 (5th
Cir. 2026) (invoking F ED. R. A PP. P. 46 and inherent powers);
Whiting v. City of Athens, 170 F.4th 455, 459 (6th Cir. 2026) (FED.
R. A PP. P. 38 and inherent authority, not Rule 46).
For Salah, as counsel of record, we elect to impose sanc-
tions under Federal Rule of Appellate Procedure 46. This rule
affords federal courts of appeals broad power to “suspend,
disbar, or discipline a member of our bar ‘for conduct unbe-
coming a member of the bar.’” Camacho-Valdez v. Garland, 30
F.4th 675, 679 (7th Cir. 2022) (quoting FED. R. A PP. P. 46(b), (c)).

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14 No. 25-1988
We invoke Rule 46 in situations where “counsel’s unbecom-
ing conduct affects other litigants or misleads the court.” Id.
(citation omitted). That includes cases where counsel makes
factual misrepresentations in briefs, whether intentional or
not. Waldon v. Wal-Mart Stores, Inc., 943 F.3d 818, 824–26 (7th
Cir. 2019) (collecting cases); see also Klein v. O’Brien, 884 F.3d
754, 757–58 (7th Cir. 2018). So, we see Rule 46 as the natural
fit for a case involving attorney misconduct that permitted un-
checked AI hallucinations to be included in a brief. Accord
Fletcher, 168 F.4th at 239 (Fifth Circuit invokes Rule 46 when
an attorney “used [AI] to draft a substantial portion—if not
all—of her reply brief”); D’Ambrosio v. Meta Platforms, Inc., No.
25-2231, 2026 WL 1361951, at *12 (7th Cir. 2026) (using Rule 46
as the basis for an order to show cause involving AI errors).
In its seminal case interpreting Rule 46, the Supreme
Court held that “conduct unbecoming a member of the bar”
is “conduct contrary to professional standards that shows an
unfitness to discharge continuing obligations to clients or the
courts, or conduct inimical to the administration of justice.”
In re Snyder, 472 U.S. 634, 645 (1985). When attorneys make
“misrepresentations, omissions, or failures of inquiry,” we
can impose sanctions—whether the attorneys are “deliber-
ately misleading the court,” “displaying egregious
misjudgment,” or even are negligent. In re Lightfoot, 217 F.3d
914, 916–17 (7th Cir. 2000) (collecting cases). In many ways,
our approach to evaluating misrepresentations parallels the
inquiry district courts conduct under Federal Rule of Civil
Procedure 11. In re Kelly, 808 F.2d 549, 551 (7th Cir. 1986) (Rule
11 “is not incorporated by reference or otherwise in any rule
of this court, but its requirements help to define conduct be-
coming a member of the bar.”).

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No. 25-1988 15
Rule 46 includes the power to impose monetary sanctions.
Camacho-Valdez, 30 F.4th at 679–80; Waldon, 943 F.3d at 825
(collecting cases); In re Boyle-Saxton, 668 F.3d 471, 472 (7th Cir.
2012) (issuing order to show cause why attorney “should not
be fined” for defying a court order). This court has fined
members of our bar under Rule 46 for submitting briefs in-
cluding statements “not well grounded in fact or law” that
“falsely impute[] a particular position to this court.” Mays v.
Chi. Sun-Times, 865 F.2d 134, 140 (7th Cir. 1989). And we have
invoked Rule 46(c) to impose monetary penalties on attorneys
who improperly certify portions of their brief, especially
when there are factual misrepresentations. In re Galvan, 92
F.3d 582, 584 (7th Cir. 1996); Waldon, 943 F.3d at 824–26.
In this case, Salah has engaged in conduct unbecoming of
members of the bar. He signed his name to a brief containing
many AI hallucinations. He admitted he did not review the
brief before submitting it. Yet he signed and submitted it, cer-
tifying that the representations in the brief were warranted by
existing law and supported by the record. That conduct alone
“display[s] egregious misjudgment” and is inimical to the ad-
ministration of justice, making it sanctionable under Rule 46.
Lightfoot, 217 F.3d at 916.
What is more, Salah did not review the second version of
the brief before submitting it—even after this court put him
on notice about its factual and legal deficiencies. Though the
false citations were changed, the revised brief still contained
unsupported assertions and at least two hallucinated quotes
from the original brief. In these circumstances, we would ex-
pect members of this court’s bar to scrutinize the brief before
re-submitting it. Salah did not take these precautions.

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16 No. 25-1988
Both versions of the brief violate Federal Rule of Appellate
Procedure 28. See McCurry v. Kenco Logistics Servs., LLC, 942
F.3d 783, 791 (7th Cir. 2019) (attorneys violate Rule 28 when
they submit briefs “laden with assertions that have no basis
in the record and arguments that have no basis in the law”).
Moreover, Salah flouted his duties to this court. “Under this
circuit’s standards for professional conduct, lawyers promise
that they will ‘not knowingly misrepresent, mischaracterize,
misquote, or miscite facts or authorities in any oral or written
communication to the court.’” Dec, 171 F.4th at 947 (quoting
this court’s Standards for Professional Conduct). It could be
debated whether Salah misrepresented the law or facts
“knowingly” in the first version of his brief. But the same can-
not be said for his second brief. Salah submitted that version
again without review, this time fully aware of the risk of er-
rors. Attorneys practicing before this court should never sign
and submit a brief they have not reviewed. That is especially
true when they know the brief might contain serious misrep-
resentations.8
For all these reasons, we impose a fine of $5,000 on Salah
under Federal Rule of Appellate Procedure 46(c). We do not
believe it is appropriate to bar him from practicing before this
court at this time, as he has no prior record of misconduct. But
Salah is on notice that the next time any incident occurs, he
could be subject to disbarment before this court. We impose
this fine to reflect the seriousness of submitting briefs
8 Salah says he failed to review the revised brief because this court
declined to postpone oral argument. Oral Arg. at 15:49. But Salah had over
three weeks from the date we alerted him to the AI hallucinations before
oral argument. That was plenty of time to identify and correct errors.

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No. 25-1988 17
containing AI hallucinations to this court, which is “inimical
to the administration of justice.” Snyder, 472 U.S. at 645.
B
Our authority to sanction Chalisa rests on other grounds.
Only “an attorney who practices before” a federal court of ap-
peals can be sanctioned under Rule 46(c). Chalisa is not ad-
mitted to this court’s bar and she did not enter an appearance
in this case. We have hesitated to sanction lawyers who are
not admitted to this court’s bar under Rule 46, even when they
technically “practice[] before” this court. Cf. Gorokhovsky v.
Stefantsova, 825 F. App’x 375, 377 (7th Cir. 2020) (“Gorokhov-
sky is not a member of our bar and therefore cannot be disci-
plined under Rule 46[(b)].”). And it is not clear that merely
writing a brief qualifies Chalisa as someone who “practice[d]
before” us in this matter.
Still, federal courts have inherent authority to “punish the
full range of litigation abuses.” Manez v. Bridgestone Firestone
N. Am. Tire, LLC, 533 F.3d 578, 591 (7th Cir. 2008) (citing Cham-
bers v. NASCO, Inc., 501 U.S. 32, 46 (1991)). That power is not
limited to attorneys who practice before this court; it reaches
anyone who engages in bad faith conduct impacting our abil-
ity to manage and decide cases. “No matter who allegedly
commits a fraud on the court—a party, an attorney, or a non-
party witness—the court has the inherent power to conduct
proceedings to investigate that allegation and, if it is proven,
to punish that conduct.” Id. at 585. We invoked this authority
to issue the order to show cause to Chalisa. After putting her
on notice of the errors and giving her an opportunity to ex-
plain herself, we can impose sanctions on her.

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18 No. 25-1988
At this juncture, though, we decline to do so. We have no
evidence that Chalisa committed fraud on this court, nor does
anything in her apologetic response indicate bad faith. In
these specific circumstances, inherent authority sanctions are
not necessary or appropriate. Nevertheless, we admonish her,
as her use of AI in drafting this brief “result[ed] in confusion
and time wasted” for this court. Dec, 171 F.4th at 948. Attor-
neys must ensure that their work product does not contain
false legal citations or factual errors, whether they enter an
appearance in the case or not.
C
Beyond the issue of monetary sanctions, we think it best
to refer this matter to the Attorney Registration and Discipli-
nary Commission of Illinois. Cnty., Mun. Emps.’s Supervisors’
and Foremen’s Union Loc. 1001 v. Laborers’ Int’l Union of N. Am.,
365 F.3d 576, 580 (7th Cir. 2004). Even after conducting our
own inquiry into the matter, questions remain as to how such
egregious errors made their way into this brief.
Chalisa correctly expressed remorse in her response to the
order to show cause. But her factual explanations are wanting.
It is unlikely that such pervasive errors would arise through a
grammar check. Moreover, the way Chalisa handled the revi-
sions process was perplexing. She claims she was “not aware
of the factual errors that remained in the petition.” At the
same time, she maintains her pre-ChatGPT draft contained no
factual errors, as far as she knew. Yet, an author familiar with
this case could not miss these glaring fact problems, especially
because they were intertwined with fabricated quotations.
An ARDC review of this case would help us to know if
Chalisa’s response to our show cause order accurately reflects

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No. 25-1988 19
the nature of her AI usage. See Ill. R. Pro. Conduct (2010) R.
3.3(a)(1) (eff. Jan. 1, 2010) (“A lawyer shall not knowingly
make a false statement of fact or law to a tribunal.”). Further,
we note some concern about whether the client consented to
the contractual agreement between Salah and Chalisa. Both
attorneys’ responses to our orders depict an agreement that
raises the possibility of an impermissible fee-splitting ar-
rangement. See Ill. R. Pro. Conduct (2010) R. 1.5(b), (f) (eff. July
1, 2023). At oral argument, Salah said “the client was aware”
other attorneys outside the firm would be “involved” in pre-
paring the brief. Oral Arg. at 6:37. But he admitted he did not
discuss the terms of Chalisa’s fee with Perez-Castillo “to that
[level of] detail.” The Illinois Rules require the client to con-
sent, in writing, to this kind of arrangement. See also Ill. R. Pro.
Conduct (2010) R. 1.2(e) (eff. Jan. 1, 2016). The ARDC may
conduct a more searching review of these questions.
IV
Because there is no merit to Perez-Castillo’s argument for
cancellation of removal, we deny his petition for review. We
also note that Perez-Castillo has not been prejudiced by the
shortcomings of his attorneys. Pure legal considerations bar
his application for cancellation of removal. Plus, a different
attorney represented him in the agency proceedings. That at-
torney waived the challenge to the immigration judge’s hard-
ship determination, undercutting this petition.
We impose monetary sanctions of $5,000 on attorney Ab-
dullah Salah under Federal Rule of Appellate Procedure 46(c)
because he failed to check the AI-hallucinated citations, legal
propositions, and factual representations in two briefs he
signed and submitted to this court. We do not impose sanc-
tions on attorney Farah Chalisa at this time.

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20 No. 25-1988
We also direct the clerk of this court to send copies of this
opinion to the Attorney Registration and Disciplinary Com-
mission of Illinois for such consideration as it sees fit. Wade v.
Soo Line R.R. Corp., 500 F.3d 559, 566 (7th Cir. 2007). Further,
we direct the clerk of court to include copies of the petitioner’s
briefs (first and second versions); Salah’s initial response to
our January 23, 2026 order alerting him to the AI hallucina-
tions; both responses to our order to show cause; and the re-
cording of the oral argument. Upon request, the clerk of court
may also forward any other documents necessary to give the
ARDC context for this matter. See United States v. Roti, 484 F.3d
934, 938 (7th Cir. 2007).
We will not discharge our show cause order until the
ARDC has had a chance to review this matter. We direct at-
torney Salah and attorney Chalisa each to file a status report
with this court informing us whether the ARDC has chosen to
investigate. Those reports should be filed one year from the
date this case is decided, or within seven days of any final ac-
tion by the ARDC, whichever comes first. At that point, we
may consider whether additional sanctions are appropriate.
There is “little doubt that litigants and courts” will de-
velop “sound and workable practices” governing AI usage in
due time, but that point has not yet arrived. Dec, 171 F.4th at
947 (quoting Jones, 164 F.4th at 970). Briefs like those peti-
tioner’s counsel submitted in this case are unacceptable and
“result in confusion and time wasted” for this court. Id. at 948.
Members of this court’s bar must be exceedingly careful about
outsourcing their work product. At all times, attorneys must
follow both the Federal Rules of Appellate Procedure and this

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No. 25-1988 21
court’s Rules of Professional Conduct. If not, sanctions may
follow.
P ETITION D ENIED WITH SANCTIONS

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