AI Citation Verification Status: How to Read "Not Located in Reporter" Verdicts
AI citation verification status is the per-citation verdict a pre-filing scanner returns on a legal brief: located, partial, or not located in the named reporter. A binary verdict on a legal citation is the failure mode the audit layer was built to replace. The lawyers in Mata v. Avianca relied on a tool that returned confident answers about cases that did not exist. The tool did not hedge. The brief was filed. The sanctions order followed.
A scanner that says only yes or no on each citation reproduces that failure mode in a different costume. The honest report has more than two states. It tells the partner what was located, what was not located, what differed from the reporter, and what could not be resolved at all. The verdicts are hedged because the underlying facts are hedged. The recommendation is direct. The verdict is honest.
Veritas returns one of seven verdict states on every citation in a draft. The taxonomy is below. For each state, what it means and what the partner does with it.
Verified
The citation resolved to an opinion in the reporter at the named volume and page. The quoted language, if any, was located in the opinion text. The cited proposition appears to be supported by the opinion. All three layers of the check returned a positive result.
The partner reads the citation in context and moves on. The verdict does not relieve the partner of judgment on whether the case is the strongest authority available. It establishes only that the cite, as written, is what the brief says it is.
Smith v. Jones, 100 F.3d 100, 105 (2d Cir. 2000)
→ Verified. Located in reporter. Quoted language matches opinion text. Proposition supported.
Citation not located
The citation does not resolve to any opinion at the named reporter, volume, and page. The reporter exists. The volume exists. The opinion described in the brief does not appear in it. This is the Mata failure mode. It is the verdict that returns on a fabricated citation produced by a generative model.
The partner does not file the brief in that form. The citation is removed, replaced, or confirmed by an independent source before the filing goes out. The verdict is the operational signal that the draft is not ready.
Doe v. Roe Industries, 300 F.4th 222 (5th Cir. 2021)
→ Citation not located. No opinion published at 300 F.4th 222 matches the cited party and circuit.
Differs from reporter
The case exists. The opinion was located in the reporter at the named volume and page. The quoted language in the brief does not match the language in the opinion. This is the second-most-common AI failure mode. The model produced a real case with a fabricated or paraphrased quotation attached.
The partner pulls the opinion and confirms the actual language. In most cases the brief is revised to match the reporter or the quotation is removed. Filing language that purports to be a quote and is not is the form of error that draws judicial attention under Rule 11.
Smith v. Jones, 100 F.3d 100, 105 (2d Cir. 2000)
→ Differs from reporter. Opinion located. Quoted language not found in opinion text. Recommend verifying the quotation against the source before filing.
Misattributed
The citation points to a real opinion, but the brief attaches the opinion to the wrong court, the wrong judge, or the wrong year. The reporter resolves. The case name resolves. The metadata in the cite does not match the metadata on the opinion.
The partner corrects the attribution. The substance of the cite may stand. The form is wrong, and the form is part of what the court reads.
Smith v. Jones, 100 F.3d 100 (9th Cir. 2000)
→ Misattributed. Opinion located. The cited opinion was decided by the Second Circuit, not the Ninth. Recommend correcting the court designation.
Withdrawn or superseded
The case existed and was published. The opinion has since been vacated, withdrawn, or superseded by a later decision of the same court or a higher court. The brief is citing dead authority. The verdict identifies the subsequent history and the source of the treatment.
The partner reads the subsequent history. In some matters the superseded authority remains useful for context or as part of a narrative. In most matters the citation is replaced with the governing decision.
Smith v. Jones, 100 F.3d 100 (2d Cir. 2000)
→ Withdrawn or superseded. Opinion located. Vacated by Smith v. Jones, 200 F.3d 200 (2d Cir. 2001). Recommend citing the governing decision.
Unable to verify
The scanner could not resolve the citation against any reporter or public-record source available to it. The verdict does not mean the citation is wrong. It means the citation cannot be confirmed. State court records, recent slip opinions, and certain administrative decisions sit outside the corpus the scanner consults. The honest verdict says so.
The partner confirms the citation by an independent path, or decides whether to file with the verdict on the certificate. The record shows that the verification ran and what it could and could not establish. That is the protection.
Smith v. Jones, No. 24-CV-1234 (S.D.N.Y. Mar. 4, 2025)
→ Unable to verify. Citation could not be resolved against the available reporter and public-record sources. Recommend confirming against the docket before filing.
Cited for unrelated proposition
The case is real. The opinion was located. The proposition the brief offers the citation for is not the proposition the opinion stands for. The model attached a holding to a case the case does not hold. This is the proposition-support failure mode. It is subtle and it is common in AI-assisted drafting.
The partner reads the opinion. The citation is removed, replaced, or the surrounding argument is rewritten to match what the case actually decides. A real case cited for a fictional holding is still a misrepresentation to the court.
Smith v. Jones, 100 F.3d 100, 105 (2d Cir. 2000)
→ Cited for unrelated proposition. Opinion located. The opinion addresses jurisdiction under the Foreign Sovereign Immunities Act. The brief offers the citation in support of a Rule 56 summary-judgment standard. Recommend substituting authority that addresses the cited rule.
The certificate carries the full taxonomy
Each of the seven verdicts is a distinct operational signal. A binary report collapses them into a single bit. The collapse is the place where the partner loses information. A Citation not located is not the same problem as a Differs from reporter, and neither is the same problem as an Unable to verify. The recommended next step is different in each case. The risk to the filing is different in each case.
The Verification Certificate carries the full taxonomy. Each citation in the draft is listed with its verdict, the source records consulted, and a recommendation. The partner reads the certificate before signing the brief. The certificate goes into the matter file alongside the filing.
The product does not write the brief. The product does not format the citations. The product runs the verification and returns the verdict. The taxonomy is what makes the verdict useful.