# Romero v. Corona Investments: the Seventh Circuit found 'an astonishing number of hallucinated citations' — and declined to sanction anyway

> In In re Romero (Romero v. Corona Investments, No. 25-2021, 7th Cir. July 16, 2026), the appellant moved to strike an appellee brief he said contained quotations that were 'the fruit of artificial intelligence hallucinations.' The court stopped short of striking the brief or imposing sanctions, lodging only a 'general reminder' about care and diligence — while a dissent noted the brief 'included an astonishing number of erroneous and even hallucinated citations' by named counsel and would have imposed sanctions.

- Verification status: verified
- Case type: deployment
- Provider: Generative artificial intelligence (unspecified)
- Client: U.S. Court of Appeals for the Seventh Circuit — In re Romero (Romero v. Corona Investments, LLC), No. 25-2021, Courts / legal (AI-governance honest-negative) (named)
- Sector: legal / US / cross
- Verified on: 2026-08-24
- Canonical URL: https://theinternetninja.com/stories/romero-v-corona-investments-7th-cir-bach-ai-hallucinated-citations-admonished-no-sanction-511a-2026/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| Motion to strike / sanctions over 'artificial intelligence hallucinations' denied — no sanction imposed |  |  |
| Panel lodged only 'a general reminder that the court expects members of our bar to exercise care and diligence' |  |  |
| Dissent: brief 'included an astonishing number of erroneous and even hallucinated citations' by named counsel Paul M. Bach |  |  |

## Verification method

Court-adjudicated public record. Primary is the Seventh Circuit's July 16, 2026 opinion in No. 25-2021 (Scudder, J.; Hamilton, J., dissenting), retrieved from CourtListener and byte-tied to its Wayback capture (sha1-b32 SK4UDVNUN3WKWOW7NNMTZ33NX7I7T55X). The critical AI facts — the non-sanction and 'general reminder,' and the dissent's 'astonishing number of erroneous and even hallucinated citations' — are corroborated firsthand by Credit Slips (archive-bound) and Bloomberg Law (live-verified firsthand; its Wayback snapshot is a paywall shell, so archive-bound corroboration is one independent).

## Full case file

## The problem

*In re Bernardo Romero* was, on its face, a technical Chapter 13 bankruptcy fight over the interest rate owed to an Illinois property-tax purchaser — whether an appellee's secured claim is a "tax claim" under 11 U.S.C. § 511(a) and, if so, what rate applies [source](https://storage.courtlistener.com/pdf/2026/07/16/bernardo_romero_v._corona_investments_llc.pdf). But more than three months after oral argument, the debtor-appellant, Bernardo Romero, filed a motion to strike portions of the appellee's brief, alleging its quotations were "the fruit of artificial intelligence hallucinations" [source](https://storage.courtlistener.com/pdf/2026/07/16/bernardo_romero_v._corona_investments_llc.pdf). This is a court-origin AI-governance honest-negative sitting at the tolerance edge of the fabricated-citation vein: a federal appeals court confronting a brief laced with what it called the fruit of AI hallucinations — and choosing not to punish it.

## The outcome

Writing for the panel, Judge Scudder declined to act: "After reviewing the submissions, we stop short of striking Corona's brief or imposing sanctions" [source](https://storage.courtlistener.com/pdf/2026/07/16/bernardo_romero_v._corona_investments_llc.pdf). The court reasoned that any errors "may reflect a lack of care on Corona's part, but they did not materially affect the presentation of the appeal," and closed with only a caution: "to lodge a general reminder that the court expects members of our bar to exercise care and diligence in preparing their briefs" [source](https://storage.courtlistener.com/pdf/2026/07/16/bernardo_romero_v._corona_investments_llc.pdf). Bloomberg Law reported the same outcome firsthand: the Seventh Circuit "rejected a request to strike the brief or impose sanctions on Paul M. Bach of Bach Law Offices" [source](https://news.bloomberglaw.com/bankruptcy-law/appeals-court-warns-bankruptcy-lawyer-over-alleged-ai-citations).

## The dissent that would have punished it

Judge Hamilton, dissenting on the merits, went further on the AI question. He wrote that "Corona's briefing in this case included an astonishing number of erroneous and even hallucinated citations," named the responsible attorney — "the sloppy errors by Corona's lawyer, Paul M. Bach of Bach Law Offices, made this court's work more difficult than it should have been" — and argued punishment was warranted: "Sanctions like those we have imposed in other recent cases involving hallucinated citations from generative artificial intelligence would be appropriate here, regardless of the precise reasons for the many errors" [source](https://storage.courtlistener.com/pdf/2026/07/16/bernardo_romero_v._corona_investments_llc.pdf). Prof. Pamela Foohey, writing at Credit Slips, independently reported the episode, quoting the same "astonishing number of erroneous and even hallucinated citations" and characterizing the panel's response as a light tap on the wrist [source](https://creditslips.org/2026/07/21/a-light-tap-on-the-wrist-for-ai-use-misuse/). Bloomberg Law likewise described a brief containing what one judge called "an astonishing number" of citations that were "incorrect or possibly hallucinated by artificial intelligence" [source](https://news.bloomberglaw.com/bankruptcy-law/appeals-court-warns-bankruptcy-lawyer-over-alleged-ai-citations). No AI product is named in the opinion, and counsel did not admit AI use — the "fruit of artificial intelligence hallucinations" language is the court's own characterization of the disputed quotations, not an adjudicated finding of AI use.

## On the merits

On the underlying question the panel affirmed the bankruptcy court: the applicable interest rate "is 18% and comes from 35 ILCS 200/21-15 of the Illinois Property Tax Code," treating the tax-sale purchaser's claim as a "tax claim" under § 511(a) rather than applying the Till market rate [source](https://storage.courtlistener.com/pdf/2026/07/16/bernardo_romero_v._corona_investments_llc.pdf). The NACTT Academy's bankruptcy-practice digest independently reports that "under section 511 of the Bankruptcy Code the purchaser was entitled to 18% interest," though it covers only the merits and not the AI episode [source](https://considerchapter13.org/2026/07/26/does-tax-sale-purchaser-hold-tax-claimor-secured-debt-divided-seventh-circuit-says-tax-claim/).

## A note on the weakest link

The critical facts rest on the strongest possible source — the Seventh Circuit's own signed opinion (Tier 1), byte-tied to its Wayback capture — so the secondary newsrooms only corroborate; they are not load-bearing. The honesty caveat is on corroboration *weight*: the AI facts are carried firsthand by two independent newsrooms, but only one of them, Credit Slips (a legal-academic group blog, not a general-circulation newsroom), is archive-bound. Bloomberg Law carries the same facts firsthand in its live article, but Bloomberg serves the Wayback crawler a paywall shell that captures none of the body — so archive-bound corroboration honestly sits at *one* independent, not two. No claim here asserts that AI was adjudicated to be the cause; the record's value is precisely that it is a *non*-sanction.

## How this was verified

- **Method:** Tier-1 court-origin opinion (No. 25-2021, decided July 16, 2026, Scudder, J.; Hamilton, J., dissenting), retrieved from CourtListener storage and byte-tied to its Wayback capture (`20260805144302`; sha1-b32 `SK4UDVNUN3WKWOW7NNMTZ33NX7I7T55X`, 202,567 bytes). Every quoted line was re-matched against the pdf-parse extraction of that capture.
- **Corroboration:** the critical claims (court declined to strike or sanction, "general reminder" only; dissent's "astonishing number of erroneous and even hallucinated citations") are carried firsthand by Credit Slips (archive-bound, Wayback `20260722141020`) and Bloomberg Law (live-verified firsthand; its Wayback snapshot is a paywall shell). Archive-bound corroboration is one independent; the merits-only NACTT Academy digest corroborates the § 511(a) / 18% holding.
- **Date verified:** checker round 2, 2026-08-05 (confidence 1.000; graduated to `pending`).
- **What "verified" (green) would still require:** a human confirming on the Seventh Circuit record (No. 25-2021) that the July 16, 2026 opinion stands as issued (no rehearing or en-banc disturbance), and ideally a second *archive-bound* newsroom carrying the AI facts firsthand. Green never depends on the AI-implicated attorney confirming anything. This page is `pending` (amber); no green badge is claimed.

## Related case files

- [Whiting v. City of Athens (6th Cir.)](/stories/whiting-v-city-of-athens-sixth-circuit-fake-citations-15000-punitive-sanction-each-attorney-2026/) — a contrasting appellate outcome on the same fact pattern: where the Seventh Circuit here admonished but declined to sanction, the Sixth Circuit imposed a $15,000 punitive sanction on each attorney.
- [United States v. Hayes](/stories/us-v-hayes-federal-defender-1500-sanction-fictitious-citation-court-declines-to-find-ai-use-2025/) — the same "court declines to find AI use" family: a fictitious citation sanctioned while the court expressly declined to hold that AI was the cause.
- [In re Nwaubani (4th Cir.)](/stories/in-re-nwaubani-4th-cir-standing-panel-attorney-discipline-ai-fabricated-citations-public-admonishment-2026/) — another appellate court that opened a discipline case over citations "potentially derived from generative artificial intelligence" but declined to decide whether AI was used, imposing only a non-monetary sanction.

## Sources

1. U.S. Court of Appeals for the Seventh Circuit · *In re Romero (Romero v. Corona Investments, LLC)*, No. 25-2021 (decided July 16, 2026; Scudder, J., for the panel, Hamilton, J., dissenting) · 2026-07-16 · https://storage.courtlistener.com/pdf/2026/07/16/bernardo_romero_v._corona_investments_llc.pdf — **Tier 1** (primary, signed appellate opinion; independent-origin, not counted toward corroboration; byte-tied to Wayback capture 20260805144302, sha1-b32 SK4UDVNUN3WKWOW7NNMTZ33NX7I7T55X).
2. Credit Slips (Prof. Pamela Foohey) · "A Light Tap on the Wrist for AI Use/Misuse?" · 2026-07-21 · https://creditslips.org/2026/07/21/a-light-tap-on-the-wrist-for-ai-use-misuse/ — **Tier 2** (independent legal-academic commentary carrying the AI facts firsthand; archive-bound, Wayback capture 20260722141020).
3. Bloomberg Law (James Nani) · "Appeals Court Warns Bankruptcy Lawyer Over Alleged AI Misuse" · 2026-07-16 · https://news.bloomberglaw.com/bankruptcy-law/appeals-court-warns-bankruptcy-lawyer-over-alleged-ai-citations — **Tier 2** (independent newsroom carrying both critical facts firsthand; live-verified this session, but its Wayback snapshot is a paywall shell, so it is not archive-bound and does not lift corroboration above one independent).
4. NACTT Academy / considerchapter13.org · "Does Tax Sale Purchaser Hold Tax Claim or Secured Debt? Divided Seventh Circuit Says Tax Claim" · 2026-07-26 · https://considerchapter13.org/2026/07/26/does-tax-sale-purchaser-hold-tax-claimor-secured-debt-divided-seventh-circuit-says-tax-claim/ — **Tier 2** (independent bankruptcy-practice digest; corroborates the § 511(a) / 18% merits holding only, not the AI episode).
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