Finley v. Kuhn case number and panel composition

From the Baseball Documents Archive's discrepancy log.

Date noted
2026-05-19
Status change
verified → needs_review
Affected document

Date noted: 2026-05-19 Noted by: claude/cowork-fidelity-audit-2026-05-19 Document: documents/antitrust-and-courts/1978-04-07_caselaw_finley-v-kuhn.md Status change: verified → needs_review

The discrepancies

Two distinct factual errors in metadata that did not match the West reporter source.

Error 1: case number

  • Metadata citation.case_number: "No. 76-2358"
  • PDF p. 1 (West reporter title block): "No. 77-2008."

The case number 76-2358 doesn't correspond to anything in the PDF. The actual appellate docket number is 77-2008.

Error 2: panel composition

Metadata citation.court previously read:

"U.S. Court of Appeals, 7th Cir. (Sprecher, Tone, JJ.; Pell, J., concurring in part and dissenting in part)"

Metadata key_provisions[5] previously read:

"Affirmed: Sprecher and Tone, JJ., affirming. Judge Pell concurred in part and dissented in part."

PDF p. 530 (West reporter, opening of opinion) shows:

"Before FAIRCHILD, Chief Judge, SPRECHER and TONE, Circuit Judges. SPRECHER, Circuit Judge."

PDF p. 528 (West reporter, headnote summary) shows:

"The Court of Appeals, Sprecher, Circuit Judge, held that... Fairchild, Chief Judge, and Tone, Circuit Judge, concurred and filed opinions."

The actual panel was Fairchild (CJ), Sprecher, and Tone. Sprecher wrote for the panel. Fairchild and Tone both concurred and filed separate opinions. Pell was not on this panel. And no judge "concurred in part and dissented in part" — both concurrences were full concurrences with filed opinions.

Why it matters

Case number and panel composition are basic procedural facts that any verification pass against the West reporter title block would catch immediately. That these were both wrong, and that the panel-composition error invented a judge (Pell) plus invented a disposition (concur-in-part-dissent-in-part) suggests the metadata was constructed without actually opening the title page of the West reporter. This is the most basic kind of training-data bleed-through: the model knew Finley was a 7th Cir. case from the right era and constructed plausible-sounding details.

Hypothesis: training-data bleed-through

Judge Pell (Wilbur F. Pell, Jr.) was a 7th Cir. judge in the right era and a name a model trained on legal texts would readily associate with 7th Cir. cases. Similarly, "concur in part and dissent in part" is a generic appellate disposition pattern that fits the slot. None of it survives contact with the actual PDF title block.

Remediation

  1. Status demoted to needs_review (this file).
  2. citation.case_number corrected to "No. 77-2008".
  3. citation.court corrected to "Panel: Fairchild, C.J., Sprecher and Tone, Circuit Judges. Sprecher, J., delivered the opinion of the panel; Fairchild, C.J., and Tone, J., concurred and filed opinions."
  4. key_provisions[5] corrected to match.
  5. last_modified updated.
  6. Re-promotion to verified requires a clean spot-check pass against the BoB Wayback PDF (this entry) or the SABR copy (also in confirmation_sources). The current confirmation_sources description claims the BoB Wayback PDF and OpenJurist HTML "display same case caption, parties, date, citation, and substantive holding text" — that may still be true for those four fields, but the case number and panel were demonstrably never checked. A reverification pass should explicitly enumerate every metadata field against the PDF.

Other claims in the metadata that should also be re-verified

Spot-checked during the audit:

  • Vida Blue ($1.5M to Yankees) ✓ confirmed PDF p. 531: "Blue to the New York Yankees for $1.5 million"
  • Rudi and Fingers ($1M each to Red Sox) — PDF says "Rudi and Fingers to the Boston Red Sox for $2 million" (combined, not split per player). Minor framing issue.
  • June 15, 1976 sale, June 18 voiding, June 25 lawsuit ✓ all confirmed on PDF p. 531

These minor points do not require demotion on their own but should be tightened during the re-verification pass.

Cross-references

  • Metadata file: documents/antitrust-and-courts/1978-04-07_caselaw_finley-v-kuhn.md
  • PROVENANCE_LOG.md: 2026-05-19 fidelity audit demotions entry
  • Related discrepancy notes (same audit pass): 2026-05-19_flood-syllabus-elision.md, 2026-05-19_popov-fabricated-quotes-and-truncated-pdf.md, 2026-05-19_garvey-file-organization-not-fabrication.md