Legal Citation Management System
Depends on: FTR-15 — Project Cache
What this is
A structured, end-to-end system for managing legal citations in any litigation project — from the moment a case is first proposed through verified-and-safe-to-file status. The system maintains a Citation Vetting Report (CVR) as the authoritative, versioned register of every authority in the project. Every citation has a status. No citation enters a filing without a status. No filing goes out with a status below VERIFIED.
The system handles the specific failure mode that creates the greatest filing risk in AI-assisted legal drafting: hallucinated or mischaracterized citations. AI models can confidently produce case names, reporter citations, and holdings that are entirely fabricated, partially fabricated (real case name + invented page numbers), or real cases whose holdings are the opposite of what was stated. This system catches all three before they reach a court filing. A separate, standalone feature from Legal Preferences / Motion Branding Spec (FTR-18) — that feature covers document formatting; this one covers citation integrity. No overlap between the two.
Why this exists
Legal citations carry unique risk compared to other factual claims in an AI-assisted workflow:
- Fabrication risk. AI models generate citations that do not exist — a plausible case name, a plausible reporter volume and page, a plausible holding. The citation looks correct. It is not.
- Mischaracterization risk. The case is real, the citation is accurate, but the holding stated is wrong — sometimes completely reversed. The case says the opposite of what was claimed.
- Page number risk. The case is real and the holding is correct, but the reporter page numbers were generated rather than verified from a primary source. Filing a citation with an unverifiable page number is an ethics and credibility issue.
- Verification lag risk. A citation is used in early drafts, looks fine, accumulates across multiple documents, and by the time anyone checks it, it has been embedded in five places. Finding and correcting it becomes a multi-document surgery.
The CVR system solves all four by requiring status assignment before any citation reaches a filed document — and tracking status centrally so that every document in the project pulls from one authoritative register.
Status taxonomy
Every citation in the CVR has exactly one status at all times:
| Status | Meaning | Safe to file? |
|---|---|---|
| VERIFIED | Opinion text confirmed from a primary source. Holding confirmed as stated. Reporter cite or docket-only cite confirmed. | Yes |
| TBV | To Be Verified. Citation has been used in a draft but has not yet been confirmed from a primary source. Holds the place; flags for verification. | No |
| FLAG | Case is real and holding is plausible, but a specific element — usually a reporter page number — could not be confirmed from free sources. Requires Westlaw or LexisNexis pull before filing. | No — manual verification required |
| DROP | Citation has been verified and found to be fabricated, mischaracterized, page-number-unverifiable, or holding-inverted. Permanently removed from all drafts. Never cite. | Never |
No intermediate statuses. No "probably fine." Every citation is one of these four.
The Citation Vetting Report (CVR)
The CVR is the authoritative register. It is a versioned Markdown file maintained in the project's research strategy folder. Every citation in every document in the project must appear in the CVR with a current status.
File naming: [ProjectCode]_Citation_Vetting_Report_v[X.X].md
CVR structure:
[PROJECT] CITATION VETTING REPORT — v[X.X]
[Case name / matter] | [Court]
Version: X.X | Date: YYYY-MM-DD
Verification sources used: [list]
BEFORE FILING ANY DOCUMENT: Every case in the WESTLAW PULL LIST must
be confirmed before filing. All DROP cases must be removed from drafts.
DO NOT cite any case with FLAG status until manually verified.
## MASTER STATUS TABLE
| # | Case | Citation | Status | One-Line Holding | Action |
|---|------|----------|--------|-------------------|--------|
| 1 | [Name] | [Reporter or docket] | VERIFIED | [Holding in one sentence] | [Ready to file / Cite by docket / See note] |
| 2 | [Name] | [Reporter or docket] | TBV | [Claimed holding] | [What needs to be done] |
## DROPPED CASES — FULL REGISTRY
DROPPED — [Case name]
Claimed citation: [What we had]
Status: DROP — [FABRICATED / MISCHARACTERIZED / HOLDING INVERTED / PAGE NUMBER UNVERIFIABLE]
Source confirmed: [URL or "Could not be located"]
What we claimed it said: [Our original holding statement]
What it actually says / Why it was dropped: [Full explanation]
Date dropped: [Date] | Reason identified by: [How found]
## WESTLAW PULL LIST — PRIORITY ORDER
| Priority | Case | What to confirm | Westlaw search string |
|----------|------|------------------|------------------------|
| #1 CRITICAL | [Case] | [Specific element] | [Search string] |How the workflow runs
Step 1 — Citation is proposed
A citation enters the project in one of two ways:
- AI-generated: Claude or another AI model produces a case citation as part of research, a brief, or a motion draft.
- Human-provided: The operator introduces a citation from memory, from prior research, or from a secondary source.
Either way, the citation is entered into the CVR immediately with status TBV. It is not placed in any filed document until Step 2 is complete. If it appears in a draft before verification (which happens in practice), the draft is marked with a ⚠️ TBV flag next to the citation and the CVR entry notes "in draft — unverified."
Step 2 — Automated verification attempt
Claude attempts to verify the citation using free primary sources in this order:
- Google Scholar (
scholar.google.com) — full opinion text searchable by case name - Justia (
law.justia.com) — full opinions for most state and federal courts - CourtListener (
courtlistener.com) — federal and many state courts - Caselaw Access Project (
cite.case.law) — Harvard's digitized reporters - FindLaw (
findlaw.com/cases) — secondary source; confirms existence and general holding - State appellate court websites — many courts post opinions directly by docket number
What Claude checks during automated verification:
- Does the case exist under the cited name?
- Does the cited reporter volume and page match what is found at the primary source?
- Does the court and year match?
- Does the holding, as stated in the CVR, accurately represent what the opinion actually says?
- Is the case still good law — no subsequent history that reverses or limits the cited point?
If all elements confirm → status changes from TBV to VERIFIED. If the case exists but a specific element (usually the exact reporter page number) cannot be confirmed from free sources → status changes to FLAG and the case goes on the Westlaw Pull List. If the case cannot be located under the cited name, the holding is wrong, or the holding is inverted → status changes to DROP. A full explanation is written into the Dropped Cases section of the CVR.
Step 3 — Manual verification (FLAG cases only)
FLAG cases require a manual pull from Westlaw or LexisNexis. The operator or a licensed attorney runs the search using the Westlaw search string provided in the CVR's Westlaw Pull List. The pull confirms or corrects:
- Exact reporter volume and opening page
- Parallel cites if any
- Pin cites used in the brief
- Subsequent history via KeyCite or Shepard's
After the manual pull, the status updates to VERIFIED (with the confirmed cite noted) or DROP (if the pull reveals the case cannot support the proposition cited). Until a manual pull has been run, FLAG cases do not appear in any filed document.
Step 4 — CVR version bump
Every time a citation changes status — TBV→VERIFIED, TBV→FLAG, TBV→DROP, FLAG→VERIFIED, FLAG→DROP — the CVR is version-bumped (e.g., v3.6 → v3.7), the prior version is archived, and the new version is synced to the project cache. The Agent Instructions document records the current CVR version and its summary counts (e.g., "33 VERIFIED | 7 DROP | 0 FLAG").
Step 5 — Pre-filing gate
Before any document is converted to PDF for filing, Claude runs a pre-filing citation check:
- Pull the current CVR.
- For every citation in the document, confirm its CVR status.
- Any citation with status TBV or FLAG → STOP. Do not generate the filing PDF. Flag for resolution.
- Any citation with status DROP → STOP. Citation must be removed from the document first.
- All citations VERIFIED → proceed to PDF.
This gate is enforced even if the citation "looks fine." Looking fine is not verification. The CVR is the authority.
Cite-by-docket vs. cite-by-reporter
For recent cases — particularly Court of Appeals opinions from the last several years — official reporter citations may not yet be assigned or may not be verifiable from free sources even though the opinion itself is publicly available. In those cases the system uses docket-number citation as the verified form:
Hawbaker v. Brittingham, No. A24A0611 (Ga. Ct. App. Oct. 4, 2024)
This is a complete, accurate, and professionally acceptable citation. It does not require a reporter page number. It is verifiable from the court's published docket. When a reporter citation becomes available and is confirmed from a primary source, the CVR is updated and the cite form in the document changes accordingly.
The rule: never cite a reporter page number that has not been confirmed from a primary source. Docket-only citation is always preferable to a page-number-unverifiable reporter cite.
Multi-AI research synthesis integration
This system is designed to work with a multi-model research workflow in which the same research question is run through multiple AI platforms (e.g., Claude, ChatGPT Deep Research, Gemini Deep Research) and their outputs are synthesized before anything enters the CVR.
The synthesis step catches one specific failure mode: platform-specific fabrication. A citation that one model generates with high confidence may not appear in the other models' outputs at all — which is a strong signal of fabrication. The synthesis rules are:
- A citation that appears in only one platform's output → enters CVR as TBV — elevated priority (single-source; verify first).
- A citation that appears consistently across multiple platforms with consistent holding → enters CVR as TBV — standard priority.
- A citation whose holding is directly contradicted across platforms (one says it supports you, another says it doesn't) → enters CVR as TBV — CONFLICT and is elevated to manual verification regardless of other factors.
No output from any single AI platform, however authoritative it appears, bypasses verification. Multi-platform synthesis reduces the probability of a fabricated citation reaching the CVR in the first place. Verification confirms it didn't.
Assess first
- Confirm the project type involves legal citations or authoritative references that need to be traceable to primary sources. This feature is designed for legal proceedings but the same structure applies to any project where cited sources must be independently verifiable — academic, regulatory, or policy work.
- Check for an existing CVR file in the project. If one exists, read it and carry it forward. Do not start a new CVR — merge and version-bump.
- Check the Agent Instructions for any existing citation status summary. If one exists, reconcile it with the CVR.
- Identify the jurisdiction and court. Verification sources that are most complete vary by jurisdiction — state appellate opinions vary widely in free-source coverage; federal circuit opinions are best covered on CourtListener.
- Confirm the project cache is set up (this feature syncs the CVR there on every version bump) — if Project Cache isn't installed yet, note that as a prerequisite rather than skipping the sync step silently.
Ask, only if needed
- "Does this project already have a Citation Vetting Report? If so, share it and I'll carry it forward. If not, I'll start one now from scratch or from any citations already in your drafts — which would you prefer?"
- "What platform do you have access to for manual verification — Westlaw, LexisNexis, or both? This determines how I label FLAG cases in the pull list."
- "Do you want the pre-filing citation gate enforced automatically on every document conversion, or do you want to run it manually before each filing?"
Write
- Create
[ProjectCode]_Citation_Vetting_Report_v1.0.mdin05_research\strategy\(or the project's equivalent research folder). Populate it with all citations currently in any project draft — every one starts at TBV. - Run automated verification on every TBV citation using the source priority list above. Update statuses. Version-bump the CVR.
- Produce the Westlaw Pull List for all FLAG cases, in priority order.
- Remove all DROP cases from every draft document. Document each removal in the CVR's Dropped Cases section with a full explanation.
- Add this section to
admin\AGENT_INSTRUCTIONS.md:
◆ CITATION MANAGEMENT SYSTEM
CVR file: 05_research\strategy\[ProjectCode]_Citation_Vetting_Report_v[X.X].md
Current status summary: [X] VERIFIED | [X] TBV | [X] FLAG | [X] DROP
Manual verification platform: [Westlaw / LexisNexis / both]
CITATION RULES (non-negotiable):
- Every citation in every document must appear in the CVR with a current
status.
- No citation with TBV or FLAG status may appear in any filed document.
- No citation with DROP status may appear in any document, draft or filed.
- Cite-by-docket is always preferred over an unverified reporter page
number.
- Before any document is converted to PDF for filing: run the pre-filing
citation gate. Pull the CVR. Confirm every citation is VERIFIED. Any TBV
or FLAG = stop and resolve first. Any DROP = remove from document first.
- When the CVR is updated (status change, new citation, case dropped):
version-bump the CVR, archive the prior version, sync to project cache,
update the status summary line in AGENT_INSTRUCTIONS.md.
- Multi-AI synthesis rule: single-source citations (appears in only one
platform's output) = TBV elevated priority. Conflicting outputs across
platforms = TBV — CONFLICT, elevated to manual verification regardless
of other factors.Confirm
Confirm: the Citation Vetting Report is live at [path], all existing citations have been assigned a status, DROP cases have been removed from all drafts, the Westlaw Pull List contains [N] cases requiring manual verification, and the pre-filing citation gate is active. Want to install another feature, or is that everything?