Courts on AI / Fabricated or misquoted citations

Loyer v. Wayne County Michigan

United States District Court for the Eastern District of Michigan · Federal district courts · MI · 2026-04-28 · No. 4:21-cv-12589-SDK-CI · order

Fabricated or misquoted citations

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 Cromer to show cause why he should not be referred to the State Bar for discipline after failing to submit proof of ordered ethics-seminar attendance.
Recorded conduct: Counsel Ronnie Cromer filed a response brief with multiple fictitious, differently cited, or misquoted authorities and admitted that a generative artificial intelligence engine supplied the bogus case law. The court ordered him to show cause regarding referral. — outcome: pending; 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.

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

United States court documents are public domain; the topic coding, disposition line and summary are SafeLegalAI's reading of the document for comparison, not a finding about any person named in it. This record summarises a public court document or official publication and reports what it says; SafeLegalAI makes no findings of its own. Individuals and organisations are named only as they appear in that public record. Anyone named may send a right of reply, correction or contextual update (for example an appeal, vacatur or later disposition) via /report; we add a dated note where appropriate. Reply or correct this record.

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub