ga-fact-check

Fact-Check Georgia Court Filings

NOT LEGAL ADVICE. Fact-checking detects citation and consistency errors but does not assess legal sufficiency. Verify substantive law independently before filing.

Use this skill before any Georgia court filing leaves the desk. It is the deeper evidentiary-citation pass; it runs four passes.

Pass 1 — Citation verification

For every rule, statute, regulation, and case citation in the document, verify four things: (a) the authority exists and is cited accurately; (b) it is still good law (not repealed, superseded, overruled, or distinguished); (c) the pinpoint is correct; and (d) the cited text actually says what the brief claims.

Georgia citation conventions

Georgia follows its own appellate citation conventions (Georgia Supreme Court Rule 22; Court of Appeals Rule 24). Georgia is not a public-domain / neutral-citation jurisdiction — there is no [YEAR] GA [###] vendor-neutral cite. Cite the official reporters first, with the regional reporter as a parallel cite second:

• Supreme Court of Georgia: official Georgia Reports (Ga.) first, then South Eastern Reporter (S.E.2d) parallel second.
• Court of Appeals of Georgia: official Georgia Appeals Reports (Ga. App.) first, then S.E.2d parallel second.
• Order of a full cite: Name, Vol. Ga. Page, Vol. S.E.2d Page (year).
• With a pincite (point to the official-reporter page first, then the parallel page): 261 Ga. 491, 493, 405 S.E.2d 474, 476 (1991).
• Not-yet-reported opinions (no Ga./Ga. App. volume yet): cite by case name + docket/case number + the decision date, e.g. Name, No. S21A0001 (Ga. Mar. 1, 2021).
• Statutes: O.C.G.A. § 9-11-56 (always the §; the official code is the Official Code of Georgia Annotated).
• Court rules: Uniform Superior Court Rules (USCR), Uniform State Court Rules, Uniform Magistrate Court Rules — cite by rule number, no §.
• Federal statutes: 15 U.S.C. § 1692g.

Common errors to flag:

• Dropping the official Ga. / Ga. App. reporter and citing only the S.E.2d parallel — Georgia practice leads with the official reporter.
• Confusing the courts: Ga. is the Supreme Court, Ga. App. is the Court of Appeals. A case in Ga. App. cited as Ga. (or vice versa) is a real red flag.
• Inventing a neutral cite ([YEAR] GA [###]) — Georgia has none.
• Missing the § on an O.C.G.A. citation, or adding a § to a USCR rule citation (rules take no §).
• A pincite that points to the parallel S.E.2d page only, with no official-reporter pincite.

Where to verify

The official O.C.G.A. text is published by LexisNexis and is paywalled/copyrighted — do not rely on scraped "official" text. Use these open verification sources instead:

• O.C.G.A. sections (current): https://codes.findlaw.com/ga/ (codes.findlaw.com/ga) — good for confirming a section exists and reading current statutory text.
• Case law: CourtListener — court IDs ga (Supreme Court of Georgia) and gactapp (Court of Appeals of Georgia). Confirms the case exists, the reporter volume/page, and the parties.
• Case pages: Justia case pages corroborate parties and citations, but Justia 403s automated fetches — expect to open it manually rather than fetch it programmatically.

For live verification, prefer the bundled CourtListener and Legal Data Hunter MCP servers (shipped via the shared federal dependency). They can confirm a case exists, surface the reporter citation, and check subsequent-history / good-law status without scraping paywalled or bot-gated sites.

Known-good Georgia anchors

These citations are verified and may be relied on as anchors. If a draft cites a Georgia proposition, prefer anchoring it to one of these where it fits, rather than to an unverified cite:

• Summary judgment — Lau's Corp., Inc. v. Haskins, 261 Ga. 491, 405 S.E.2d 474 (1991). Celotex-style standard under O.C.G.A. § 9-11-56; movant may point to the absence of evidence.
• Equitable distribution of marital property — Stokes v. Stokes, 246 Ga. 765, 273 S.E.2d 169 (1980). Georgia is an equitable-distribution (not community-property) state.
• Credit card account = written contract — Hill v. American Express, 289 Ga. App. 576, 657 S.E.2d 547 (2008).
• Debt-buyer standing / unbroken assignment chain — Nyankojo v. North Star Capital Acquisition, 298 Ga. App. 6, 679 S.E.2d 57 (2009). Go-to for attacking debt-buyer standing.
• Debt-buyer account-stated / business-records foundation — Wirth v. CACH, LLC, 300 Ga. App. 488 (2009); Rutledge v. Gemini Capital Group, LLC, 327 Ga. App. 454 (2014).
• Open default — "proper case" prong — Bowen v. Savoy, 308 Ga. 204 (2020) (O.C.G.A. § 9-11-55).

Re-verify reporter pincites. Some reporter pin-cites in secondary sources have been flagged for re-verification (notably the parallel S.E.2d cites associated with the Hill / American Express line). Before filing, re-verify every reporter pincite — especially the parallel S.E.2d page — against an authenticated database (CourtListener or a paid reporter service), not against a secondary summary.

Red flags — hallucinated / AI-generated citations

Treat any of these as a stop-and-verify signal:

• A case that does not exist. No hit on CourtListener (ga / gactapp) for the party names + reporter cite. AI tools fabricate plausible-looking Georgia cites; assume nothing is real until the reporter volume/page resolves to the named parties.
• Wrong reporter for the court. A Supreme Court holding cited to Ga. App., or a Court of Appeals decision cited to Ga. — the court and the official reporter must match.
• Mismatched parallel cite. The Ga./Ga. App. cite and the S.E.2d cite resolve to different cases or different years.
• Repealed / superseded statute sections:
  • The pre-2016 garnishment provisions at O.C.G.A. §§ 18-4-110 through 18-4-118 are REPEALED (the garnishment article was rewritten effective 2016) — a cite into that old numbering is a dead section.
  • The pre-2013 Georgia evidence numbering (old Title 24) is superseded by the new Evidence Code (e.g., business records moved from former § 24-3-14 to § 24-8-803(6)). Flag any cite to the old Title 24 numbering.
• Invented neutral cite. Any [YEAR] GA [###] style cite is fabricated — Georgia has no neutral citation.

Pass 2 — Internal consistency

Within a single document, verify:

• Dates: every date is consistent across all its appearances (date of service, date of contract, date of last payment, etc.).
• Dollar amounts: every amount is consistent and the totals add up (principal + interest + fees + costs = total demanded).
• Defined terms: a term defined with (the "Account") is used consistently throughout — no slipping into "the loan" or "the debt" once defined.
• Party names: each party named consistently (no switching among "Plaintiff", "Plaintiff Smith", and "Smith").
• Cross-references: every "see paragraph X" or "see Exhibit Y" resolves to something that exists at the cited location.
• Numbered paragraphs: sequential, with no gaps or duplicates.

Pass 3 — Packet consistency

Across the multi-document filing packet (motion + affidavit + proposed order + certificate of service):

• Caption identical in every document: court name, county, case number, and party names must match exactly.
• Document title matches in the certificate of service and the proposed order's title bar.
• Dates align: the certificate of service date matches the signature date on the motion; the affidavit's "sworn to" date aligns with when it was executed before the notary.
• Relief sought matches: the motion's prayer ("WHEREFORE, [movant] respectfully requests ____") must mirror the proposed order's ordering language ("IT IS HEREBY ORDERED that ____").
• Exhibits referenced in the motion are listed in the affidavit and physically attached.
• Filing path: confirm the destination court's e-filing route is consistent across the packet (the same county clerk / portal).

Pass 4 — Sworn vs. argued

Compare what is sworn in the supporting affidavit against what is argued in the motion or brief:

• Every factual assertion in the argument should be either (a) supported by a citation to an affidavit paragraph, (b) admitted in the pleadings, or (c) a matter of judicial notice.
• Identify any factual claim in the motion that is not supported by the affidavit — that gap must be fixed before filing.
• Identify any factual claim in the affidavit that is not used in the motion — decide whether it belongs there at all.
• Verify the affidavit's personal-knowledge foundation — flag any paragraph that begins "I believe" or "I understand" without a stated basis, since affidavits must rest on personal knowledge.

Output format

When invoked on a packet, produce a structured report:

FACT-CHECK REPORT — [Document title / Case number]

Pass 1 (Citations)
  PASS  O.C.G.A. § 9-11-56                 — exists; correct subsection
  WARN  Hill v. American Express,          — re-verify S.E.2d parallel
        289 Ga. App. 576, 657 S.E.2d 547     pincite against an
        (2008)                               authenticated database
  FAIL  O.C.G.A. § 18-4-112                — REPEALED (pre-2016
                                             garnishment numbering)
  FAIL  Smith v. Jones, 300 Ga. 12         — no such case found on
                                             CourtListener (court ga)

Pass 2 (Internal consistency)
  PASS  Defined terms used consistently
  WARN  Paragraph numbering jumps from 6 to 8

Pass 3 (Packet consistency)
  PASS  Caption matches across motion, affidavit, proposed order
  FAIL  Motion seeks $4,500 in fees; Proposed Order awards $4,000

Pass 4 (Sworn vs. argued)
  FAIL  Motion ¶ 3 asserts "Plaintiff sent a 30-day notice"; no
        corresponding affidavit paragraph

Summary: 6 PASS / 2 WARN / 4 FAIL — DO NOT FILE until 4 FAILs resolved.

Composition

• ga-quality-check — the lighter pre-filing format-and-content pass; this skill is the deeper evidentiary-citation pass.
• ga-draft-motion — when a fact-check turns up a missing or bad authority, re-draft the affected section.
• ga-consumer-debt — for verifying the debt-buyer / written-contract anchors (Nyankojo, Wirth, Rutledge, Hill) in a collection matter.
• ga-family-law — for verifying the equitable-distribution anchor (Stokes) and custody / support statutory cites.
• ga-law-references — the canonical Georgia corpora (court rules, O.C.G.A. statutes, and the shared federal symlinks) to verify cites against.