Hypocritic Medicine: Why the Supreme Court needs CitationClerk

In our last post, we walked through Mata v. Avianca, the famous AI-hallucination case. CitationClerk successfully flagged all eight of the brief's fabricated citations.

But CitationClerk does more than find hallucinations. It works the way a clerk would. Using regular software (not AI), it reads each citation, pulls the real opinion or statute, and compares what the brief says against the source. Because it reads the source, it catches ordinary mistakes too, mistakes that have nothing to do with AI.

One of these mistakes was in a Supreme Court opinion. It was signed by a sitting Justice, and run through the Supreme Court's own printing and proofreading. The Court published it with a citation defect anyway.

The mistake can be found on the fifth page of the dissent in Nos. 25A1207 & 25A1208, 608 U. S. ___ (2026) (Alito, J., dissenting). The asterisk footnote cites Alliance for Hypocritic Medicine v. FDA. The real case name is Alliance for Hippocratic Medicine. The party name is misspelled, but because "Hypocritic" is itself a real word, spellcheck slides right past it.

But the misspelling was the easy part. The case the footnote points to is no longer on file under that name at all, and that is where an ordinary citation check quietly fails.

What CitationClerk found

We ran the dissent through CitationClerk to see if it would catch the mistake:

CitationClerk read the party name as written, resolved the docket against the public record, and found the case on file. It reported the case as real and flagged the name as a brief-quality observation. But there was an added difficulty: the real case was under a different name.

The docket the footnote points to, No. 2:22-cv-223 in the Northern District of Texas, is no longer captioned Alliance for Hippocratic Medicine at all. After the Supreme Court held in 2024 that the original plaintiffs lacked standing (FDA v. Alliance for Hippocratic Medicine, 602 U. S. 367), the suit continued on the strength of the intervenor States, and the district court's live docket now reads State of Missouri v. FDA. Same docket number, same court, but a different name on the caption.

That is exactly where a name-based lookup breaks. A reader searching the current docket for "Hippocratic" — never mind "Hypocritic" — would not find it. CitationClerk resolves the bare docket number against the public record, so it lands on the right case no matter which name you start from: the misspelling in the brief, the caption it was filed under, or the caption it carries today.

The same name, spelled correctly

Elsewhere in the same dissent, the case name is spelled correctly. CitationClerk passes it clean:

Why standard tools missed the typo

Lawyers usually check their citations with a citator like Shepard's or KeyCite. Those tools are built around the reporter citation, the triple of volume, reporter, and page that looks like "602 U. S. 367," and they exist to answer one question: is this authority still good law? Whether the party name is spelled correctly is a different question, and not one they were built to ask.

That leaves two gaps here. Alito's dissent gives a bare docket number, "No. 2:22-cv-223," so there is no reporter for a citator to look up in the first place. And even where a reporter cite is present, the spelling of the caption goes unchecked. CitationClerk reads the name as written, resolves the cite against the case-law databases, checks the name against the full party list, finds "Alliance for Hippocratic Medicine" as a plaintiff, and flags the misspelling as a brief-quality observation.

Due diligence, even for your own writing

If a citation typo can be found even in a Supreme Court dissent, then the problem was never only careless lawyers. Everyone who writes makes mistakes. The job is to catch them before they reach the public.

CitationClerk is regular software, not an AI model. It is designed to be a reliable second pair of eyes, and to catch the mistakes that slip through the cracks of ordinary proofreading.