Courts on AI / Fabricated or misquoted citations

Boyle, et al. v. Steven Kramer

United States District Court for the Eastern District of Michigan · Federal district courts · MI · 2026-05-28 · No. 25-13857 · order

Fabricated or misquoted citationsGAI

On 2026-05-28, in Boyle, et al. v. Steven Kramer, the Eastern District of Michigan warned that future filings containing fabricated legal authorities may lead to sanctions. A self-represented litigant submitted a filing using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Disposition: The court warned that future filings containing fabricated legal authorities may lead to sanctions.
Recorded conduct: A self-represented litigant submitted a filing using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support. — 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.

2026) (stating that citing “even a single fake case” is sanctionable conduct). And when litigants misrepresent the law, they waste judicial resources. Pro se litigants who have engaged in similar behavior have been subjected to sanctions such as the striking of filings with factitious citations, dismissal of the case, and monetary penalties. See Sanders, 176 Fed. Cl. at 170 (collecting cases); Evans v. Robertson, No. 24-13435, 2025 WL 3126852, at *4 (E.D. Mich. Nov. 7, 2025) (striking filings with factitious citations); Ali v. IT People Corp., Inc., No. 2:25-CV-10815, 2025 WL 2682622, at *3 (E.D. Mich. Sept. 19, 2025) (ordering the plaintiff to pay $200.00 to the defendant’s attorney for each factitious citation). The Court warns Plaintiffs that factitious citations will not be tolerated and that they may be sanctioned if future filings contain factitious citations, including but not limited to striking of filings or dismissal. III. Conclusion For the reasons set forth above, Plaintiffs’ objections are OVERRULED. (ECF No. 25.) IT IS SO ORDERED. Dated: May 28, 2026 s/Judith E.

Authorities cited in the passage: Evans v. Robertson, No. 24-13435, 2025 WL 3126852, at *4 (E.D. Mich. Nov. 7, 2025) · Ali v. IT People Corp

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Read from the Charlotin CC0 public mirror of the court-authored document; official copy is pending.

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