Courts on AI / Fabricated or misquoted citations
Gregory Hardy v. K. Jones, et al.
U.S. District Court for the Eastern District of Michigan · Federal district courts · MI · · 2026 WL 801202 · No. 25-12718 this Court recommended in a repo · report and recommendation
On 2026-03-23, U.S. District Court for the Eastern District of Michigan struck the motion and issued a final sanctions warning after the plaintiff repeated fake quotations previously attributed to AI use. A self-represented party submitted a motion with false quotations, including Berndt v. Tennessee and United States v. Frazier.
- Disposition
- The court struck the motion and issued a final sanctions warning after the plaintiff repeated fake quotations previously attributed to AI use.
- Recorded conduct
- The motion used false quotations, including Berndt v. Tennessee and United States v. Frazier, which the court found nonexistent, misquoted, or unsupported. — 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.
R&R). The R&R explained, “Courts and opposing counsel Gregory Hardy, Flint, MI, Pro Se. are [ ] burdened by the careless use of AI by pro se filers.” Hardy v. Whitaker, ___ F.R.D. ___ 2026 WL 575225, at *10. Bennet J. Bush, Genesee County Corporation Counsel, Flint, Hardy apologized for his “inclusion of inaccurate citations MI, for Defendants Bennett, Jay Parker, Danielle Macko, generated by an AI tool” in his objection to the R&R. Fuller. Case No. 24-cv-11270, ECF No. 213, PageID.2430. But he repeated the offense in his motion to consolidate. ORDER STRIKING PLAINTIFF'S More recently, the Sixth Circuit emphasized that the “even MOTION AND GIVING A FINAL a single fake case can be sanctionable” and that “citing WARNING OF SANCTIONS (ECF NO. 33) fake cases can harm the reputation of judges and courts whose names are falsely invoked as authors of the bogus ELIZABETH A. STAFFORD United States Magistrate Judge opinions and the reputation of a party attributed with fictional conduct.” Whiting City of Athens Tennessee, ___ F. 4th ___, *1 Plaintiff Gregory Hardy, proceeding pro se and in forma 2026 WL 710568, at *4 (6th Cir. Mar.
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