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Courts on AI / Fabricated or misquoted citations

Jane Doe, et al. v. Lincoln Consolidated Schools, et al.

U.S. District Court for the Eastern District of Michigan · Federal district courts · MI · · No. 2:23-cv-11236 · opinion

Fabricated or misquoted citations

On 2026-03-23, U.S. District Court for the Eastern District of Michigan granted summary judgment in part and ordered plaintiffs’ counsel’s firm to reimburse the defense costs of researching the hallucinated case. Counsel submitted a brief with multiple fabricated or nonexistent authorities, including Doe v. Univ. of Mich., No. 18-11914.

Disposition
The court granted summary judgment in part and ordered plaintiffs’ counsel’s firm to reimburse the defense costs of researching the hallucinated case.
Recorded conduct
The brief used multiple fabricated or nonexistent authorities, including Doe v. Univ. of Mich., No. 18-11914, which the court found nonexistent, misquoted, or unsupported. — outcome: costs order; actor: lawyer
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.

63, PageID.783. Plaintiff’s response is that they did not use AI to complete their briefing; instead, the Frankenstein citation appears to result from multiple case citations inadvertently being combined during efforts to condense their brief. ECF No. 66, PageID.984. The Court notes that it, too, could not find the case, Doe v. Univ. of Michigan, as originally cited, and the four cases Plaintiffs offer from which they believe the truncated citation formed do not appear to support their implication that Courts adopt the ELCRA or Title IX frameworks in analyzing claims under § 26, specifically. In fact, none of those cases contained any references to Article I, § 26 whatsoever. Further, the numbers and date following the original Doe v. Univ. of Mich. citation are missing from the citations for the four cases that Plaintiffs claim were part of the original string citation, which they should have included if it were a true “Frankenstein” citation. Based on this, the Court is not persuaded that Plaintiffs did not allow the inclusion of an AI hallucinated citation in their brief without checking that the citation supported the entirety of their proposition or

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