Courts on AI / Fabricated or misquoted citations

Jones v. Taylor

United States District Court for the Eastern District of Michigan · Federal district courts · MI · 2026-04-22 · No. No. 2:25-cv-10681 · opinion

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: Jones’s extension-and-abeyance motion was denied, the case was dismissed without prejudice as to eleven unserved defendants, the amended complaint with reconsideration motion was struck, and Jones was warned about future fake citations or misrepresentations.
Recorded conduct: Jones’s pro se response cited Tokio Marine & Fire Insurance Company v. Flota Mercante Grancolombiana, S.A., 35 F.3d 1134 (6th Cir. 1994), which was not a real case, and United States v. Robinson, 305 F.3d 732, 735 (6th Cir. 2002), which appeared to be another AI-generated fake case. — 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

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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