Courts on AI / Fabricated or misquoted citations
Eric Tobler v. Stephen Tobler, et al.
United States District Court for the Eastern District of Michigan · Federal district courts · MI · · No. 25-13384 Honorable Judith E. Levy Magistrate · order
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 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 reply brief with one false case quotation, including Bunner v. Blow-Rite Insulation Co. — 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