Generators must never originate citations.

There are two ways to keep fabricated citations out of a brief: detect them after a model writes them, or make them impossible to write. Detection has to win every time. Across a brief with 35 cited propositions, a checker that misses 2 percent of defects lets roughly half of all briefs through with at least one, and making nineteen briefs in twenty fully clean would demand per-citation accuracy of about 99.85 percent on judicial prose. Construction never plays that game. If no model is permitted to originate a citation, and every authority in the document traces to a retrieved record, the fabrication rate is zero by construction, whatever the length.

The architectural rule has a precise form. Citation stages contain no generative models, and generative stages emit no citations. Language models may compose prose from retrieved, verified material; they may not mint authority, and there is no setting that lets them. The guarantee lives in code, not in a prompt the model may or may not follow.

The rule moves risk rather than abolishing it. Construction pushes the hardest remaining failures into retrieval: a system that cannot fabricate can still fail to retrieve the controlling case, return the right case for the wrong stage, or misjudge its direction. That is why this thesis sits beside the theses on omission, posture and direction rather than replacing them.

But it removes one failure class entirely and makes every remaining error traceable to a record. A fabricated citation is the one failure no review gate reliably catches at 2 a.m. The right response is to make it unrepresentable rather than merely detectable.