Heriberto Perez-Castillo v. Todd W. Blanche

── Heriberto Perez-Castillo v. Todd W. Blanche ── Court: Court of Appeals for the Seventh Circuit Date: June 01, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 25-1988 HERIBERTO PEREZ-CASTILLO, Petitioner, v. TODD W. BLANCHE, Acting Attorney General of the United States, Respondent. ____________________ Petition for Review of an Order of the Board of Immigration Appeals. No. A206-788-938 ____________________ ARGUED FEBRUARY 17, 2026 — DECIDED JUNE 1, 2026 ____________________ Before BRENNAN, Chief Judge, and RIPPLE and TAIBLESON, 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 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. 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. Federa