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Courts on AI / Fabricated or misquoted citations

Loyer v. Wayne County Michigan et al.

United States District Court for the Eastern District of Michigan · Federal district courts · MI · · No. 21-12589 Honorable Shalina D. Kumar Magistrate · order

The Eastern District of Michigan on 2026-04-28 ordered counsel to attend an ethics seminar and file proof of attendance after finding AI-supplied bogus case law in Loyer v. Wayne County Michigan et al. Counsel filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation.

Disposition
The court ordered counsel to attend an ethics seminar and file proof of attendance after finding AI-supplied bogus case law.
Recorded conduct
Counsel filed a brief with one fabricated case citation, one false case quotation, and one mischaracterized case citation. — outcome: other; 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.

Kumar Magistrate Judge Curtis Ivy, Jr. ORDER TO SHOW CAUSE Counsel for plaintiff, Ronnie E. Cromer, Jr. (“Cromer”) filed a response brief containing multiple citations that were entirely fictitious, had different citations, and/or did not contain the quote or content attributed to them. See ECF No. 50. Cromer admitted at a hearing before the Court on March 12, 2025, that he used a generative artificial intelligence engine (AI) to draft that brief, that AI supplied the bogus case law cited, and that he did not review or cite check that case law before filing his brief. Due to Cromer’s negligent conduct in this case, the Court ordered him to attend the ethics seminar offered by the State Bar of Michigan on April 8, 2025, Case 4:21-cv-12589-SDK-CI ECF No. 73, PageID.

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