Hardy v. Whitaker

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cases and to avoid congestion in the calendars of the District 100% 100% Courts.” Link v. Wabash R. Co., 370 U.S. 626, 629–30 (1962). Exercising that power is increasingly important in the wake The office of the Eastern District of Michigan's Court of the exploding use of generative AI. Damien Charlotin, a Administrator provided the data in the above charts. The legal analyst, has tracked more than 500 legal decisions about “filings” in the charts reflect the number of complaints rather AI-generated hallucinated content in the United States. 7 than the number of documents filed by pro se plaintiffs. But The hallucinated content is “typically fake citations, but also the Court has observed that non-prisoner pro se plaintiffs other types of AI-generated arguments.” Id.; see also Sanders are increasingly likely to clog dockets with frivolous and v. United States, 176 Fed. Cl. 163, 169 (2025) (“It is no improper documents. secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen The sharp increase in frivolous pro se filings burdens a rash of cases in which both counsel and pro se litigants have the Court. See In re McDonald, 489 U.S. 180, 184-185 cited such fake, hallucinated cases in their briefs.”). (1989) (“Every paper filed with the Clerk of this Court, no matter how repetitious or frivolous, requires some portion Likely because of the availability of AI, non-prisoner pro se of the institution's limited resources. A part of the Court's filings have skyrocketed in this district and circuit, and such responsibility is to see that these resources are allocated in Hardy v. Whitaker, --- F.R.D. ---- (2026)

Authorities cited in the passage: s MSJ included the citation · the court identified it as a fabricated/phantom case likely produced by generative AI and flagged it as a hallucination. || Fabricated: Case Law | Plaintiff · Thompson v. City of Lebanon, 813 F.3d 318, 323 (6th Cir. 2016) · the court listed this as one of several fake citations and suspected AI-generated hallucination. || Fabricated: Case Law | Plaintiff · Wesley v. Rigney, 860 F.3d 931 (6th Cir. 2017) · phantom cases · Plaintiff's MSJ included the citation 'Patel v. City of Ferndale · Plaintiff's MSJ included the citation 'Thompson v. City of Lebanon · Plaintiff's MSJ included the citation 'Spurlock v. Satterfield · Plaintiff's MSJ included the citation 'Wesley v. Rigney · Link v. Wabash R. Co · Sanders are increasingly likely to clog dockets with frivolous and v. United States