--- name: ga-fact-check description: > Use to verify the citations in a Georgia court filing before it is filed. Triggers include "check my Georgia citations", "verify this O.C.G.A. cite", "is this Georgia case real", "fact-check my brief", "Bluebook Georgia citation format", "check the Ga. App. parallel cite", "is this O.C.G.A. section still good law", "audit the authorities in my Georgia motion". Runs four passes: (1) citation verification against canonical Georgia sources; (2) internal consistency within a single document (dates, dollar amounts, defined terms); (3) packet consistency across motion + affidavit + proposed order + certificate of service; (4) sworn-versus-argued consistency between affidavit assertions and motion arguments. version: 0.1.0 --- # 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document, verify four things: (a) the authority **exists** and is cited accurately; (b) it is **still good law** (not repealed, superseded, overruled, or distinguished); (c) the **pinpoint** is correct; and (d) the cited text actually says what the brief claims.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.