cite-check

name	cite-check
description	Cite-checks a brief, motion, or memo (PDF/Word): verifies each cited case is real, supports the proposition, is good law, and quoted accurately. Returns one marked-up .docx with comments and redlines.
metadata	{"version":"0.2.0","author":"midpage"}

Cite-check

Audit every citation in an uploaded document against ground truth, and hand back one deliverable: a .docx that recreates the document exactly, marked up with Word comments and tracked-change suggestions. AI-drafted briefs invent cases, misstate holdings, and alter quotes; human drafts cite stale law and miscite the record. Every citation gets checked through the Midpage tools and every finding lands in the document itself, anchored where it occurs. Read references/citations.md for citation form and references/legal-docx.md for the renderer (including the D.review() comment/redline helpers).

Workflow

1. Intake (PDF or Word)

Read the uploaded file faithfully — full text, in order: for a PDF, extract the text; for a .docx, read the document body. Then extract every authority: case citations (with the proposition each is cited for and any quotation attributed to it) and record citations (ECF numbers, page/¶ pins, declarations, exhibits). Build the complete citation inventory before checking anything — exhaustiveness starts here; a citation missed at intake is a citation never checked. If the document is a federal filing, note the court and docket number from the caption; ask for the docket if record cites are present and you don't have it.

2. Run the five checks — on every citation, no exceptions

Work citation by citation; run independent analyzeOpinion calls in parallel. Never assert a cite is good until a tool confirms it this session.

1. The case is real. Resolve via analyzeOpinion — reporterCitation exactly as cited, or the docket tuple (court abbreviation + docket number, no "No." prefix) for unpublished cases, or a known opinionId. Set question to the cited proposition so the same call feeds check 2. Resolves → real; use the returned citation and url. Won't resolve → Review: it may be a fabrication or a case the resolver missed — the attorney must check. Never substitute a "corrected" cite from memory. A real but mis-formatted cite that still resolves: existence confirmed, formatting flagged with the tool's exact citation string as the suggested correction. WL / LEXIS / other commercial-database citations: Midpage cannot verify a citation to another commercial database. Resolve the case itself (by case name + court/docket tuple) and run the remaining checks against the version Midpage has; the comment must say so (see Comment format). Any suggested correction uses the reporter or docket-number citation the tool returns — never WL/LEXIS.
2. The proposition isn't mischaracterized. Check **doesNotAddress first** — if the document's point is listed, the case does not stand for it → Fix (the most damaging miscite). Otherwise match against supportedPropositions: honor scope qualifiers; central reliance on a background/secondary_matter match → Review (weak support); a concurrence or dissent (opinionSection) sold as the court's holding → Fix. A fair-but-aggressive reading the tool can't settle → Review, saying what the case actually supports.
3. Treatment / favorability. treatment negative (reversed, overruled, criticized) → Fix, flagged prominently; caution → Review. Separately: does the case actually help the position citing it? Positive treatment with a holding that cuts against the use → Review, explained.
4. Quotes are verbatim. Compare each quotation to the verified quote in supportedPropositions; if not covered, findInOpinion with keywords from the quote. Verbatim → OK. Altered → Fix with the correct language. Not found → Review (keyword search can miss) — never assert a quote is accurate just because the case exists.
5. Record cites (federal filings, docket provided). analyzeDocketReport to locate the entry (missing from the docket → Fix), then analyzeDocketFiling asking whether the cited content is actually in that filing. Present → OK; absent or different → Fix, noting what the filing actually says. No docket / not federal → every record cite is Review with a comment that it could not be checked without the docket.

3. Build the marked-up .docx (the deliverable)

One Word document, rendered through scripts/legal_docx.js, in three layers:

Cover page (centered, then a page break):

• Title: Midpage Cite Check
• Subtitle: the filing name, Party X v. Party Y, Case No. XX-XXXXX (from the document's caption; leave a clearly marked placeholder for anything the document doesn't supply — never invent it).
• Scope line (one or two lines, only what's needed): which portions of the document were reviewed if not the whole thing (e.g. "Scope of this review: the facts section (¶¶ 8–11, pp. 5–6) and the argument section (¶¶ 18–27, pp. 10–15)."), plus this fixed sentence: Pin-cite page accuracy is not verified.
• Disclaimer, exactly: This cite check only flags potential errors detected by Midpage. It is not intended to replace an attorney cite check. AI makes mistakes and outputs should be verified independently.

That is the whole cover — no "what was checked / what was not checked" essay, no methodology narration, no per-category inventory. The honesty lives where the reader needs it: each citation's own comment says what was confirmed or why it couldn't be checked, and the chat report carries the counts and the uncheckable items.

Exact recreation. Recreate the uploaded document's substantive content exactly — same text, same order, same headings, same numbering. The unmarked text must read identically to the original: recreate first, mark up second. You may omit a table of contents, table of authorities, and the case caption if present — it's the substantive content being checked. Match the document's structure with the builder API (headings via B.h1–B.h4 or bold paragraphs to mirror the original's levels; body via B.p; numbered paragraphs via B.numbered).

The markup. Every finding goes in (a) a Word comment and/or (b) an inline tracked change — nothing else, and nothing in the body text itself:

const D = require("./scripts/legal_docx.js");
const B = D.builders("brief");          // mirror the original's register
const R = D.review();                   // author: "Midpage Cite Check"

// a comment anchored to a citation:
B.p([ ...R.comment([B.t("Smith v. Jones, 999 F.3d 100 (9th Cir. 2021)")],
      "OK — cited proposition supported (core holding).\nhttps://app.midpage.ai/…") ])

// a redline suggestion (paired with a short comment explaining the basis):
B.p([ B.t("harm must be "), R.del("possible"), R.ins("likely"), B.t(".") ])

// write — passing the comments is required:
B.write("Midpage Cite Check - <filing name>.docx", [cover, body], outDir, { comments: R.comments() });

• Every citation in the inventory gets a comment — including the clean ones. A verified cite gets "OK — …" with the verified Midpage link; that is how the reader knows it was checked rather than skipped. Prefix every comment with its status: OK, Fix, or Review.
• Concrete corrections are tracked changes: a mis-formatted citation (delete the cited string, insert the tool's exact citation), an altered quote (delete the altered words, insert the verbatim language). Every tracked change gets a companion comment explaining the basis. Judgment items (won't-resolve, weak support, negative treatment, unverifiable quote) are comment-only — never "fix" what a tool didn't establish.
• Never silently change the user's text. Every alteration is a visible tracked change the attorney can accept or reject.

Comment format — short, scannable, no fat

Comments are read in a narrow margin pane. Three lines is the target; five is the ceiling.

• Line 1: the status and the finding, in plain words. Then at most 1–3 short sentences of basis — only what the attorney needs to decide. Cut tool narration ("two keyword searches found…"), case summaries, and Bluebook commentary.
• The link goes on its own line at the end. One link; the verified Midpage URL.
• Don't restate what the redline already shows. If the tracked change displays the correction, the comment states the status and the basis — not a prose description of the edit.
• Don't fix the brief in the margins. Substitute authority only if it was verified this session, and name it in one line — no editorializing.

Too long: "Fix — the case does not appear to stand for the proposition cited. Midpage's analysis of 503 B.R. 571 lists this point among matters the opinion does not address, and two keyword searches found no passage applying the preliminary-injunction standard with 'particular emphasis' on preventing dissipation…; the only 'dissipation' passage quotes the movants' own TRO motion in a footnote. Soundview concerns the automatic stay's immediate and extraterritorial effect… Verify the cited pages or substitute supported authority — e.g., verified this session: In re Netia Holdings…"

Right: "Fix — proposition unsupported. Midpage lists this point as not addressed, and keyword searches found no matching language; 'dissipation' appears only in a footnote. https://app.midpage.ai/document/in-re-soundview-elite-ltd-8496643"

Too long: "OK — case verified; quote verbatim except capitalization. Midpage confirms the sentence '…' 'courts' is lowercase mid-sentence in the original; the redline brackets the case change ('[C]ourts') per Bluebook R5.2. https://app.midpage.ai/…"

Right (the redline already shows the bracket fix): "OK — case verified; quote verbatim except capitalization. Confirm against the case: https://app.midpage.ai/document/matter-of-m4-enterprises-inc-1912384"

WL/LEXIS cite: "OK — Midpage cannot verify citations to other commercial databases, but found this case. The proposition appears supported but worth reviewing. https://app.midpage.ai/document/iovate-health-sciences-international-inc-11137541"

4. Report back in chat

A few sentences: how many citations were checked, the counts by status, the worst findings first (unresolvable cites, doesNotAddress miscites, negative treatment, altered quotes), and what could not be checked and why. Then hand over the .docx.

Honesty rules (the point of the skill)

• OK only when a tool confirmed it this session. Fix only for a concrete tool-found defect. Everything else — including any cite that won't resolve — is Review.
• Exhaustive means accounted for. Every citation in the inventory appears in the markup with a status. If something couldn't be checked (tool failure, no docket, ambiguous cite), its comment says so explicitly — a silent skip is a lie of omission.
• Never fabricate or repair a citation from memory. An unresolvable cite is a finding, not a gap to fill.
• Pin cites are out of scope — don't even attempt them. Never mark a pin cite correct or incorrect, never "correct" a page number; the cover page says so.
• Be explicit about what a tool confirmed versus what needs the attorney's judgment. This skill flags; it does not bless.