SERVESSolo · Small · Mid-sized firms
FORMATFixed-fee · 1-8 wks
JURIS.50 states + DC
BOOKINGThrough July 2026
STATUSAccepting
[ RESOURCE / CHECKLIST ]

Pre-publication Citation Audit Checklist.

Run through this checklist before any AI-assisted document leaves the firm. The verification standard from Mata v. Avianca and Park v. Kim is non-negotiable; this checklist is the workflow that satisfies it. Print it, run it, sign it, file it with the matter.

Use case:Pre-filing audit; Mata v. Avianca defence; Rule 11 / FRCP compliance; Rule 3.3 candor Category:Pre-flight & Audit Tools:Westlaw, Lexis, CoCounsel, Vincent, Lexis+ AI, CourtListener, Cornell LII

Read this first

IXSOR is not a law firm and this is not legal advice. This resource is a starting artifact you, the lawyer, customize and apply with judgment. Verify every assertion against primary sources. Cross-check against your jurisdiction’s rules and your specific situation before relying on it. Full disclaimer below.

The checklist

Print this, run through it, sign it, and file it with the matter. Each phase is sequential; do not skip ahead.

Download as PDF
PRE-PUBLICATION CITATION AUDIT CHECKLIST
─────────────────────────────────────────────────

Matter: __________________________________________
Document: ________________________________________
Drafted by: ______________________________________
Date drafted: ____________________________________
Audit performed by: ______________________________
Date of audit: ___________________________________

PHASE 1 — INVENTORY (do this once per document)
─────────────────────────────────────────────────

[ ] 1.1 List every cited authority in the document.
        Include cases, statutes, regulations, treatises, and bar
        opinions. Do not skip ones that look obvious or that you
        believe were already verified.

[ ] 1.2 For each citation, record:
        - Cite-as-given (verbatim from the document)
        - Pin-cite or page reference (if any)
        - The proposition the citation is offered to support

[ ] 1.3 Identify which citations were AI-assisted in any way:
        - Found by AI (e.g., CoCounsel research, Westlaw AI search)
        - Drafted by AI (the AI suggested the cite to support a point)
        - Reformatted by AI (the AI restated a real cite)

PHASE 2 — VERIFY EACH CITATION
─────────────────────────────────────────────────

For each citation, complete the following. Do NOT skip any.

[ ] 2.1 The case (or statute / regulation) exists.
        Search a primary-source database (Westlaw, Lexis, Cornell LII,
        CourtListener, Justia). The result must include:
        - Party names
        - Court
        - Reporter / citation
        - Year

[ ] 2.2 The citation format is correct.
        The volume, reporter, page, court, and year should match the
        Bluebook or jurisdiction-specific citation format.

[ ] 2.3 The pin-cite (if any) is real.
        Open the case and confirm that the cited page exists and that
        the cited language appears at that page.

[ ] 2.4 The case stands for the cited proposition.
        Read the relevant portion of the case (headnotes are a starting
        point; the actual reasoning controls). The proposition should
        actually appear in the case, not be inferred or invented.

[ ] 2.5 The case has not been overruled or abrogated.
        Run KeyCite (Westlaw) or Shepard's (Lexis) on every case relied
        upon. Negative treatment that the AI did not flag is itself a
        red flag.

PHASE 3 — STATUTORY AND REGULATORY VERIFICATION
─────────────────────────────────────────────────

[ ] 3.1 Each statute citation links to the current version on Cornell
        LII or eCFR.

[ ] 3.2 Each regulation citation reflects the current CFR text, not a
        repealed or amended version.

[ ] 3.3 Effective dates are correct. Where the matter requires applying
        the law as it stood at a specific time, the version cited
        matches that time.

PHASE 4 — DOCUMENT-LEVEL REVIEW
─────────────────────────────────────────────────

[ ] 4.1 Every quotation is verbatim from the source.
        Open the source and confirm word-for-word match.

[ ] 4.2 Every paraphrased proposition is supported by the cited
        authority.

[ ] 4.3 No citation in the document is unaccounted for in this audit.

PHASE 5 — RED FLAGS
─────────────────────────────────────────────────

If any of the following are present, escalate to the supervising
attorney before filing:

[ ] 5.1 An AI-assisted citation that I could not independently verify.

[ ] 5.2 A pin-cite to a page that does not exist or does not contain the
        cited language.

[ ] 5.3 A case that supports a different proposition than the one cited.

[ ] 5.4 A case that has been overruled or abrogated for the cited point.

[ ] 5.5 A "quotation" that does not appear verbatim in the source.

PHASE 6 — SIGN-OFF
─────────────────────────────────────────────────

[ ] 6.1 I have personally verified every citation in this document
        against a primary-source legal-research database.

[ ] 6.2 I have not relied on AI output to confirm any citation.

[ ] 6.3 I am prepared to defend every citation under Rule 11 (FRCP) /
        Rule 3.3 (Model Rules of Professional Conduct).

Signature: _______________________________________
Date: ____________________________________________

This completed checklist is filed with the matter as part of the firm's
audit trail. Retention period: per firm records retention policy.

How to use it

Inputs / fill-ins

Any document containing citations that will be filed with a court, sent to opposing counsel, or transmitted to a client: brief, motion, memorandum of law, demand letter, opinion letter.

What you get

Output

A signed, dated checklist filed with the matter. Documents the verification of every citation and creates an audit trail in the event of a sanctions inquiry.

Verification — what the lawyer must do

⚠ Risks and failure modes

  • Skipping the audit: Mata v. Avianca and Park v. Kim establish that the lawyer who signs the document is responsible for every citation, regardless of how the citation got there. Skipping this audit is the path to sanctions.
  • Verifying with AI: The original Mata failure was an attorney trusting AI output to verify AI-generated citations. The verification step must use a primary-source database.
  • Treating obvious citations as already-verified: Some sanctioned attorneys had real citations mixed with hallucinated ones. The hallucinated cites were the ones the lawyer did not double-check because they "looked right."

Citations and further reading