Courts on AI / Fabricated or misquoted citations
Patrick C. Shaltry v. Donna Collins, et al.
United States District Court for the Eastern District of Michigan · Federal district courts · MI · · 2026 WL 1556473 · No. 25-13704 · report and recommendation
On 2026-06-02, in Patrick C. Shaltry v. Donna Collins, et al, the Eastern District of Michigan magistrate judge recommended dismissal and noted a false Sixth Circuit citation while denying further relief. A self-represented litigant cited Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016) even though the court found the authority did not exist.
- Disposition
- The magistrate judge recommended dismissal and noted a false Sixth Circuit citation while denying further relief.
- Recorded conduct
- A self-represented litigant cited Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016) even though the court found the authority did not exist. — outcome: other; actor: litigant in person
- 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.
3 Judge Morris also noted Plaintiff's “troubling” pattern of misquotes, false quotations, and false citations throughout his briefs. This court likewise notes that in his briefing, Plaintiff stated the following proposition: “The Sixth Circuit likewise holds that a conviction on appeal is not final. Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016).” ECF No. 50, PageID.774 (emphasis in original). But that citation does not exist. The reporter leads to a Third Circuit case with a different title and having nothing to do with the issues presented, while a search for “Parris v. Pappas” turned up only a series of opinions from a District of Connecticut case, but again the subject matter appears to have nothing to do with this case. The court notes and refers this misrepresentation to the Magistrate Judge to consider in conjunction with all of Plaintiff's briefings, and her previous warning, as this case progresses. See ECF No. 43, PageID.715. Government Works.
Authorities cited in the passage: Parris v. Pappas, 844 F · Parris v. Pappas