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Courts on AI / Fabricated or misquoted citations

Alishia Monique Jones v. Ahmed Taylor, et al.

United States District Court for the Eastern District of Michigan · Federal district courts · MI · · No. 2:25-cv-10681 v. Honorable Susan K. DeClercq United · order

Fabricated or misquoted citations

The Eastern District of Michigan on 2026-04-22 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Alishia Monique Jones v. Ahmed Taylor, et al. The self-represented plaintiff filed a submission with two fabricated case citations, including Tokio Marine & Fire Insurance Company v. Flota Mercante Grancolombiana.

Disposition
The court warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions.
Recorded conduct
The self-represented plaintiff filed a submission with two fabricated case citations, including Tokio Marine & Fire Insurance Company v. Flota Mercante Grancolombiana and United States v. Robinson. — outcome: warning; actor: litigant in person
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Cf. id. at 625. Jones’s citation to Tokio Marine&FireInsuranceCompanyv. Flota Mercante Grancolombiana, S. A. , 35 F. 3d 1134 (6th Cir. 1994) is not to a real case, which suggests that Jones might be using artificial intelligence (AI) software prone to creating fake cases. And citing to cases that do not exist is a sanctionable offense. See Hardy v. Jones, No. 25-12718, 2026 WL 801202, at *1 (E. D. Mich. Mar. 23, 2026) (warning a pro se plaintiff that the court would recommend sanctions, including involuntary dismissal, for his repeated use of AI to generate fake cases); see also Whiting City of Athens Tennessee, No. 25-5424, 2026 WL 710568, at *4 (6th Cir.

Authorities cited in the passage: See Hardy v. Jones, No. 25-12718, 2026 WL 801202, at *1 (E · Tokio Marine & Fire Insurance Company v. Flota Mercante Grancolombiana, S.A., 35 F.3d 1134 (6th Cir. 1994) is not a real case and likely AI-generated · Court noted United States v. Robinson, 305 F.3d 732 (6th Cir. 2002) appears to be a fabricated citation generated by AI

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