Built for Bluebook 22nd Edition

Legal Citation Formatting That Knows the Rules of Every U.S. Jurisdiction

BluebookGenie formats legal citations with jurisdiction-specific rules for every federal and state court. It knows which jurisdictions require canonical Bluebook formatting and which require their own style — California’s Style Manual, Texas’s Greenbook, New York’s Official Reports Style, Michigan’s Uniform System, and the 15 states that have adopted public domain citation systems (Illinois, Wisconsin, Ohio, Colorado, and others). It resolves cases against CourtListener’s database of millions of opinions and generates properly formatted citations for any jurisdiction. If BluebookGenie can’t find your case, it lets you know — so you can verify the citation isn’t a hallucination.

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9M+

Court Cases

47

Jurisdictions Covered

240+

Years of Legal History (1788–Present)

Courts Are Done Warning

Sanctions for citation errors are escalating rapidly — and AI is making it worse.

2023

$5,000

Mata v. Avianca, Inc.

Lawyer submits brief with 6 fabricated cases generated by ChatGPT. Judge calls analysis "gibberish."

Benjamin Weiser, “A Man Sued Avianca Airline. His Lawyer Used ChatGPT.,” The New York Times, May 27, 2023, https://www.nytimes.com/2023/05/27/nyregion/avianca-airline-lawsuit-chatgpt.html.

2025

Removed

Butler Snow (AmLaw 100)

Partner at the 42nd-largest U.S. firm files 5 fabricated case citations. 3 attorneys removed from case.

Debra Cassens Weiss, “5 Hallucinated Cases Lead Federal Judge to Kick 3 Butler Snow Lawyers off Case,” ABA Journal, July 30, 2025, https://www.abajournal.com/news/article/5-fabricated-cases.

2026

$30,000

Whiting v. City of Athens

24+ fake citations in an appellate brief. 6x increase in sanctions in three years.

L.L.P. Tressler, “The Dangers of Artificial Intelligence: Recent Sixth Circuit Opinion Serves as a Reminder to Use Caution in the Wake of Artificial Intelligence,” Tressler LLP, https://www.tresslerllp.com/thought-leadership.

2026

~40 Errors

Sullivan & Cromwell

~40 errors including fabricated citations in a single filing by Wall Street’s most prestigious firm.

Santul Nerkar, “A.I. ‘Hallucinations’ Created Errors in Court Filing, Top Law Firm Says,” New York Times, April 21, 2026, https://www.nytimes.com/2026/04/21/nyregion/sullivan-cromwell-ai-hallucination.html.

"[They] sullied the reputation of our bar, which now must litigate under the cloud of their conduct."

Whiting v. City of Athens

"We deeply regret that this has occurred."

Andrew Dietderich, Partner, Sullivan & Cromwell — New York Times, April 21, 2026
Anatomy of a Failure — April 18, 2026

Sullivan & Cromwell’s Five-Page Apology to the Court

In In re Prince Global Holdings Limited, No. 26-10769 (Bankr. S.D.N.Y.), Sullivan & Cromwell filed an emergency motion on April 9 that contained AI-generated hallucinations across five separate filings: the Motion for Provisional Relief, the Verified Petition, the Motion for Joint Administration, the Motion Scheduling the Recognition Hearing, and two attorney declarations. The errors were caught not by S&C, but by opposing counsel at Boies Schiller Flexner.

“The Firm’s policies on the use of AI were not followed in connection with the preparation of the Motion. . . . this review process did not identify the inaccurate citations generated by AI, nor did it identify other errors that appear to have resulted in whole or in part from manual error.”

— Andrew G. Dietderich, Partner, Sullivan & Cromwell LLP

Comprehensive policies. Mandatory training. Secondary review. All failed.

From the Errata (Schedule A, Doc 25)

¶ 59: “As expressly contemplated by section 1519(b) of the Bankruptcy Code, which permits the Court to grant relief ‘on an ex parte basis,’ the” The urgent need to obtain the Emergency Order . . .

¶ 52: Calderon-Cardona v. Bank of N.Y. Mellon, 821 F.3d 161, 169 (2d Cir. 2016) (explaining that blocking rules “prohibit transfers”...) [entire citation fabricated]

¶ 34: In re Three Arrows Cap., Ltd., 2022 WL 17985951, at 10-11 (“Where the foreign representatives lack information regarding the debtor’s assets...provisional relief is appropriate”) [fabricated holding]

¶ 27: In re Three Arrows Cap., Ltd., 2022 WL 17985951, at *7; In re BYJU’s Alpha, Inc., corrected to *8

Headlines

Bloomberg Law: “Sullivan & Cromwell Apologizes to Judge for AI Hallucinations”

CNN Business: “Another ‘hallucinated’ court filing highlights the difference between Silicon Valley and the rest of the world”

The Cool Down: “Law firm that bills over $2,000 per hour apologizes for error-riddled court documents”

Source: PACER, S.D.N.Y. Bankruptcy Court, Doc 25, Filed 04/18/2026

The Bluebook Is Context-Dependent

The Bluebook is the most complex citation system in existence. It is not template-compatible — the same case can be cited differently depending on where it appears, how it's been cited before, and what court you're in.

Short Forms & Signals

Id., supra, infra, hereinafter — all context-dependent. BluebookGenie handles them automatically across your entire document.

Court-Specific Rules

Federal vs. state, circuit-specific abbreviations, historical court names. BluebookGenie knows the rules for every jurisdiction.

Subsequent History

Affirmed, reversed, cert. denied, overruled — citation signals that change over time as cases move through the system.

Cross-Reference Tracking

When you cite the same case multiple times, BluebookGenie tracks every reference and applies the correct short form.

BluebookGenie Output

User Input

osheroff v chestnut lodge maryland 1985

Resolved

Osheroff v. Chestnut Lodge, Inc., 62 Md. App. 519, 490 A.2d 720 (1985).

Source

CourtListener • Confidence: 99%

Subsequent Citation

Osheroff, 62 Md. App. at 525.

95.5% of Court Filings Contain Errors

Tracelaw audited 1,522 filings across 205 courts in March 2026.

7,274
Defects found in 94.1% of documents
Broken cross-references, Bluebook violations
327
Citation Mismatches in 12% of documents
Wrong case name, court, or year
578
Source Inconsistencies in 21.4% of documents
Cited authority doesn't support the proposition
48.6%
of citations cannot be resolved in public databases
Tracelaw Audit, March 2026

AI didn't create the citation crisis. It just made it visible.
These are the errors no one is catching — until BluebookGenie.

What BluebookGenie Does

Case Resolution

Type a partial case name, citation, or even a description. BluebookGenie resolves it against 6,583 pre-cached cases and the CourtListener database.

Bluebook Compliance

Full 22nd Edition formatting: court abbreviations, reporter names, parallel citations, pinpoint pages, and all the rules that templates can't handle.

Case History Tracking

Automatically identifies overruled, reversed, or superseded authority. Never cite bad law again.

Document-Level Processing

Upload an entire brief. Every citation is extracted, resolved, and formatted in one pass — with cross-references tracked throughout.

Anti-Hallucination

Every case is verified against CourtListener's authoritative database. If a case doesn't exist, BluebookGenie tells you — it doesn't invent one.

Supreme Court Cache

2,101 U.S. Supreme Court cases pre-cached for instant resolution. From Marbury v. Madison to the present.

Even the Best AI Fails 1 in 5 Times

Stanford and Yale researchers found that leading AI legal research tools — Lexis+ AI and Westlaw AI — hallucinate 17–33% of the time.

BluebookGenie doesn't generate citations. It retrieves them from authoritative databases. The data exists or it doesn't. There is nothing to hallucinate.

"Attorneys must personally verify all citations whether provided by generative AI or any other source."

6th U.S. Circuit Court of Appeals, Whiting v. City of Athens (2026)

AI Citation Hallucination Rates

Google Bard91.4%
GPT-4o (all errors)56.0%
GPT-429.0%
Lexis+ AI / Westlaw AI17.0%
BluebookGenie0%*

*Deterministic retrieval from authoritative databases. Cannot hallucinate by design.
Sources: Magesh et al., J. Empirical Legal Studies (2025); Linardon et al., JMIR (2025)

Never File a Brief with a Fabricated Citation

BluebookGenie is designed for law firms, law reviews, and legal departments that cannot afford to get citations wrong.

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