Courts on AI / Fabricated or misquoted citations

Eric Tobler v. Stephen Tobler

United States District Court for the Eastern District of Michigan · Federal district courts · MI · 2026-05-07 · No. 5:25-cv-13384-JEL-EAS · order

Fabricated or misquoted citations

The Eastern District of Michigan on 2026-05-07 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Eric Tobler v. Stephen Tobler, et al. The self-represented plaintiff filed a reply brief with one false case quotation, including Bunner v. Blow-Rite Insulation Co.

Disposition: The motion to quash was granted, the service deadline was extended, and Tobler was ordered to certify future citations and warned of sanctions.
Recorded conduct: Tobler’s pro se filing included a fake quote or holding from Bunner that likely came from generative AI. The court ordered citation certification for future filings and warned that noncompliant filings may be stricken or sanctioned. — 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.

But Tobler provides no factual support for his assertion that Diane Kelly told his process server that she was authorized to accept service on behalf of the firm. And the firm’s reply brief notes that Tobler’s reliance on Bunner is worse than just misplaced; Tobler included a fake quote and holding. Plaintiff hallucinates the holding and his quote from Bunner. Bunner involved the issue of whether service of process under the Michigan Court Rules was proper on a bankruptcy trustee where the defendant corporation was defunct. Bunner is not controlling or relevant to any of the issues here. Further, the Case 5:25-cv-13384-JEL-EAS ECF No.

Authorities cited in the passage: Bunner v. Blow-Rite Insulation Co

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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