Citation Check: Both Citations Fail (Drop Smith v. Jones; Fix Zhang et al.)

Interpretation: Bluebook, US federal courts; status judged as of 1 March 2025 (filing date); 2 items checked, 0 skipped. Neither citation points to the work it names. Item 1 is not Smith v. Jones, and the quoted words are not a holding of the case at that cite. Item 2 is not by Zhang.

Verification table

#	Citation as given	Exists	Errors found	Status	Quote/proposition check	Verdict	Corrected reference	Source link
1	Smith v. Jones, 512 U.S. 218 (1994) ("courts must defer to agency findings")	No (the locator resolves to a different case, MCI v. AT&T; no Smith v. Jones found there)	Case name: "Smith v. Jones" → MCI Telecommunications Corp. v. American Telephone & Telegraph Co.. Volume, page, court and year match: 512 U.S. 218, decided 17 June 1994.	Not applicable to the cited name. The real case's deference discussion rests on Chevron, which Loper Bright overruled on 28 June 2024 (before cutoff).	Not supported. The words appear only as the petitioners' contention that "the courts must defer to the agency's choice among available dictionary definitions", which the Court rejected.	Drop	If the intended authority is the real case: MCI Telecomms. Corp. v. Am. Tel. & Tel. Co., 512 U.S. 218 (1994), cited only for the holding that the FCC's modification authority does not reach detariffing. Do not cite for the quoted proposition.	Cornell LII
2	Zhang et al., Nature 2019;571:45-50	Unverified as given (the page range exists, but not under a Zhang first author)	First author: "Zhang" → Kollár (Alicia J. Kollár, Mattias Fitzpatrick, Andrew A. Houck). Title omitted in the input. Volume 571, pages 45-50, 2019 match.	Good: no correction, retraction or Crossmark update relation in the Crossref record (indexed 25 September 2026). Not confirmed on the journal page or PubMed (both failed to load).	n/a (no proposition supplied)	Fix	Alicia J. Kollár, Mattias Fitzpatrick & Andrew A. Houck, Hyperbolic Lattices in Circuit Quantum Electrodynamics, 571 Nature 45 (2019), doi:10.1038/s41586-019-1348-3 (inference: this is the intended work, since only the page range matches and the author must be changed).	Crossref record

Notes

Item 1 (drop). A web search for "Smith v. Jones" in 1994 surfaced no U.S. Supreme Court decision by that name at 512 U.S. 218 (my inference from search listings only, which I did not open; listings such as a Fifth Circuit entry and a 534 U.S. 1136 entry are unverified leads). The fetched Cornell page confirms that 512 U.S. 218 is MCI v. AT&T. In the real opinion, Justice Scalia wrote that the Commission's reading is not entitled to deference because it exceeds what the statute can bear. The quoted proposition is therefore the losing side's argument, and the case says close to the opposite. Separately, Loper Bright held that courts may not defer to an agency's reading of law merely because a statute is ambiguous. A broad "must defer" proposition is unsafe in federal court as of the cutoff in any event. Whether MCI itself has been formally cited as limited after Loper Bright was not checked (no citator access).

Item 2 (fix). The Crossref query for Nature volume 571, July 2019, returned one article at pages 45-50: Kollár, Fitzpatrick and Houck. That query returned 15 of 357 matches, so it does not rule out a differently paginated Zhang paper; the page-range match is why I treat the Kollár paper as the likely target. If the author actually meant a Zhang article, supply its title or DOI. The Crossref record lists the paper as received 15 March 2018 and published online 3 July 2019.

Summary

Drops: 1 (item 1, wrong case name and unsupported quote).
Fixes: 1 (item 2, author name and missing title).

Do next

Run KeyCite or Shepard's on MCI v. AT&T if it will be cited at all; I had no citator.
Ask the author what Smith v. Jones was meant to be, and find an authority that supports the deference proposition and survives Loper Bright.
Confirm item 2 on nature.com, PubMed and the Retraction Watch database, and confirm with the author that it is the intended paper.

Coverage