Methodology note
Per spec v0.4 §12 (Versioning Discipline), Tenth Seat opinions are immutable except for explicit errata. The unedited v1.0 opinions remain accessible in git history at commit 0d2669b (publish commit). The live v1.1 at /cases/25-5/opinion and /cases/25-5/dissent incorporates the corrections below. None of the corrections changed a doctrinal conclusion, disposition, line-up, or load-bearing argument; E1 corrected a misquoted statute, E2 corrected a historical factual claim in the dissent's closing peroration, E3 tightened a brief paraphrase to match the source.
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{
"_meta": {
"case_docket": "25-5",
"case_name": "Mullin v. Al Otro Lado",
"version_original": "1.0",
"version_corrected": "1.1",
"original_published_at": "2026-05-13",
"errata_published_at": "2026-05-13",
"discovered_by": "Focused non-reporter source review conducted before v1.0 had received any public traffic. The verify-citations tool (the §6.5 Gate 1 Pre-Publication Gate) had previously passed v1.0 with 11 verified / 5 fuzzy / 0 wrong_page / 0 not_found, because all three of these findings live outside its reach: a Public Law citation (not a reporter cite), a brief paraphrase, and a historical factual claim. The gap is the subject of spec v0.5's expansion of Gate 4 (Factual Accuracy).",
"neutrality_discipline": "Per spec v0.4 §12 (Versioning Discipline), Tenth Seat opinions are immutable except for explicit errata. The unedited v1.0 opinions remain accessible in git history at commit 0d2669b (publish commit). The live v1.1 at /cases/25-5/opinion and /cases/25-5/dissent incorporates the corrections below. None of the corrections changed a doctrinal conclusion, disposition, line-up, or load-bearing argument; E1 corrected a misquoted statute, E2 corrected a historical factual claim in the dissent's closing peroration, E3 tightened a brief paraphrase to match the source."
},
"errata": [
{
"id": "E1",
"type": "misquotation",
"severity": "minor",
"opinion": "dissent",
"approximate_line_v1_0": 25,
"original_quoted_text": "any alien who is physically present in the United States or at a land border or port of entry",
"corrected_quoted_text": "physically present in the United States or at a land border or port of entry",
"cited_source": "Refugee Act of 1980, Pub. L. No. 96-212, § 201(b), 94 Stat. 102, 105",
"source_verbatim": "an alien physically present in the United States or at a land border or port of entry, irrespective of such alien's status, to apply for asylum",
"explanation": "The v1.0 dissent purported to quote the 1980 statutory text but prepended 'any alien who is' — wording that does not appear in § 201(b) of the 1980 Act. The 'any alien who is' formulation is from the post-1996 (IIRIRA) version of 8 U.S.C. § 1158(a)(1), not the 1980 original. The dissent's line-3 opening rendered the same phrase correctly; line 25 conflated the two eras. The corrected version matches § 201(b) verbatim. The dissent's textual argument — that 1996 IIRIRA restated rather than narrowed the 1980 territorial reach — is unaffected."
},
{
"id": "E2",
"type": "factual_inaccuracy",
"severity": "minor",
"opinion": "dissent",
"approximate_line_v1_0": 83,
"original_quoted_text": "Most of its passengers died in the Holocaust.",
"corrected_quoted_text": "More than two hundred of its passengers were murdered in the Holocaust.",
"cited_source": "United States Holocaust Memorial Museum, Wartime Fate of the Passengers of the St. Louis (Holocaust Encyclopedia)",
"source_verbatim": "Ultimately, 254 St. Louis passengers were killed in the Holocaust. Just over half of them — 278 people — survived the Holocaust.",
"explanation": "The v1.0 dissent's closing peroration claimed 'Most of its passengers died in the Holocaust.' Per USHMM, 254 of the 937 passengers (≈27%) were killed in the Holocaust; about 287 survivors were admitted by Great Britain alone. 'Most' is materially inaccurate even using the narrower base of the 620 passengers who returned to the European continent (254/620 ≈ 41%). The corrected version preserves the rhetorical force of the closing without misstating the historical record. The dissent's broader point — that the 1980 Refugee Act took its shape against the memory of refugees who were turned away — is unchanged and historically accurate."
},
{
"id": "E3",
"type": "framing_tightening",
"severity": "minor",
"opinion": "majority",
"approximate_line_v1_0": 35,
"original_quoted_text": "the Department of Homeland Security responded to a surge of more than 150,000 arrivals — a roughly 70 percent increase over Fiscal Year 2014 — by adopting a practice colloquially termed \"metering.\"",
"corrected_quoted_text": "the Department of Homeland Security responded to more than 150,000 arrivals during Fiscal Year 2016 — a roughly 70 percent increase over Fiscal Year 2014 — by adopting a practice colloquially termed \"metering.\"",
"cited_source": "Pet. Br. 7",
"source_verbatim": "Those ports encountered more than 150,000 aliens in Fiscal Year 2016, a 70% increase over Fiscal Year 2014.",
"explanation": "The v1.0 majority described 150,000 as 'a surge,' which could be read as a single event rather than the FY2016 annual count documented in the petitioner's brief. The corrected version mirrors the brief's framing. This is the threshold case for whether the errata mechanism reaches non-misquotation framing slips; we are including it under the discipline that paraphrases of factual claims should match the source they implicitly cite. Subsequent framing-tightening errata should be reserved for cases where the original phrasing could mislead a reader, not for editorial preference."
}
],
"notes": {
"unverified_not_corrected": [
"Two parenthetical citations in v1.0 remained unverified at the time of this errata and were left in place for v1.1: (a) the majority's 'see H. R. Rep. No. 96-608, p. 17 (1979)' citation in Part III for the entry-fiction-awareness premise — the 1979 House Report on the Refugee Act is a real document but the page-17 specific claim was not independently verified; (b) the majority's transcript pin cites 'Tr. of Oral Arg. 32-35, 62-65' (justiciability/vacatur) and 'Tr. of Oral Arg. 48-49' (port-of-entry preferable to unlawful crossing) — the substance of both is supported by the transcript text, but the exact page pins were not mapped against the PDF page layout. Both are flagged as v1.0/v1.1 known follow-ups and may be revisited in a future erratum if found incorrect."
],
"spec_alignment": "This errata revealed a gap in the §6.5 Pre-Publication Gates: the verify-citations tool (Gate 1) reaches reporter-cited quotations only, and Gate 4 (Factual Accuracy) as written in v0.4 did not explicitly require a non-reporter-source pass (statutes, briefs, historical facts, transcript pins). The Mullin v1.1 corrections were caught by manual review rather than by the gate. Spec v0.5 expands Gate 4 to require a grep-and-verify pass against per-case documents and non-reporter authorities for every factual claim implicitly attributed to a source. See `docs/the-tenth-seat-spec-v0.5.md` §6.5 Gate 4 (revised) and Failure-Mode Catalog (revised)."
}
}