Chilingarian v Blanche
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Chilingarian v Blanche concerns three petitions for review of Board of Immigration Appeals (BIA) decisions denying protection from removal under the Convention Against Torture (CAT). On October 20, 2026, the Tenth Circuit denied review largely because of inadequate briefing, while rejecting the preserved challenge to severance of the cases. It also identified nonexistent authorities and a misattributed quotation that appeared to be generated with AI. The order does not establish admitted AI use or impose a separate monetary AI sanction.[1]
Immigration proceedings and review
As recounted in the order, an immigration judge granted CAT protection from removal to Russia to members of the Chilingarian family. On DHS’s appeal, the BIA severed Siranush, Siuzanna and Karen Chilingarian’s cases from Artur Chilingarian’s, denied the three petitioners’ CAT claims, and remanded Artur’s case for further proceedings. The court’s decision concerns those three petitions, not a final appellate disposition of Artur’s separate case.[1]
October 20, 2026 disposition
The court declined to consider the merits of the petitioners’ due-process and asserted BIA legal-error claims because their briefing did not develop the arguments adequately. It also treated the challenge to denial of CAT protection on the existing record as abandoned. It rejected the preserved severance argument, finding no abuse of discretion: CAT requires an individual showing and does not provide derivative protection merely because a family member qualifies.[1]
Citation errors and suspected AI use
Pages 11–12 and footnote 6 identify two nonexistent cases and a quotation attributed to Goldberg v. Kelly that does not appear in that opinion. The court said the errors appeared to result from generative AI and reiterated lawyers’ responsibility to verify their work. It also expressed concern that the reply had not adequately remedied a citation problem identified by the government and that counsel had not filed an errata notice.[1]
The denial rests on the stated briefing and severance analysis; the AI discussion is not a finding that every argument or filing was AI-generated. The order states that it is nonprecedential except under law-of-the-case, res judicata and collateral-estoppel doctrines, while permitting citation for persuasive value under the applicable appellate rules.[1]