Hardy v. Genesee County Community Action Resource Department, et al. (2)

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

R&R explained, “Courts and opposing counsel are [ ] burdened by the careless use of AI by pro se filers.” Hardy v. Whitaker, ___ F.R.D. ___ 2026 WL 575225, at *10. Hardy apologized for his “inclusion of inaccurate citations generated by an AI tool” in his objections to the R&R. Case No. 24-cv-11270, ECF No. 213, PageID.2430. But he repeated the same offense in his motion to consolidate. More recently, the Sixth Circuit emphasized that the “even a single fake case can be sanctionable” and that “citing fake cases can harm the reputation of judges and courts whose names are falsely invoked as authors of the bogus opinions and the reputation of a party attributed with fictional conduct.” Whiting City of Athens Tennessee, ___ F. 4th ___, 2026 WL 710568, at *4 (6th Cir. Mar. 13, 2026) (cleaned up). Thus, district courts may sanction the misuse of AI under Federal Rule of Civil Procedure and their inherent authority. Id. at *5. Hardy’s misuse of AI in his motion to consolidate is not his only repeat transgression. The R&R in Hardy v. Whitaker also discussed how he had filed umpteen frivolous motions. Hardy v. Whitaker, ___ F.R.D. ___ 2026 WL 575225, at *4-*7, *12-*13. Because Hardy’s motion to consolidate falsely claims that this Court has a duty to address his mental capacity, the motion is frivolous. Thus, the Court STRIKES Hardy’s motion to consolidate (ECF No. 77). B. Hardy moved before to compel discovery and to determine the