Courts on AI / Fabricated or misquoted citations
Potterf v. Wessels
United States District Court for the Eastern District of Michigan · Federal district courts · MI · · No. 1:26-cv-10860-MFL-PTM · order
The Eastern District of Michigan denies the Potterfs’ objections after they acknowledge using artificial intelligence to prepare them. The court identifies false quotations, nonexistent cases and mischaracterized authorities, declines to grant relief on Rule 11-violating objections, and warns that future false citations may bring sanctions.
- Disposition
- The court overruled objections, adopted the report and recommendation, denied plaintiffs' motions, and warned about future sanctions.
- Recorded conduct
- Self-represented plaintiffs used AI to prepare objections with false quotations, nonexistent United States v. Abdi and Hill v. Synder citations, and mischaracterized cases. — outcome: warning; 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.
The Potterfs are not entitled to relief on any of their objections because they failed to take reasonable steps to ensure that the legal citations in the objections were accurate. As the Potterfs acknowledged during the virtual hearing on August 20, 2026, they used artificial intelligence to prepare their objections. Perhaps for that reason, their objections attribute false quotations or non-existent legal principles to their cited cases. For example: • The Potterfs quoted the Supreme Court as saying in United States v. Sineneng-Smith, 140 S. Ct. 1575, 1579 (2020), that federal courts “do not as a rule initiate torts or explore legal pathways on their own, but rather sit as arbiters of legal issues presented and argued by the parties.” ... That quotation does not appear in the Sineneng-Smith case in any form. • The Potterfs argued that “the Sixth Circuit clarified in United States v. Abdi, 827 F.3d 533, 538 (6th Cir. 2016) ...” That case does not appear to exist.
Authorities cited in the passage: United States v. Sineneng-Smith, 140 S. Ct. 1575 (2020) · United States v. Abdi, 827 F.3d 533 (6th Cir. 2016) · Van Houten v. City of Fort Worth, 827 F.3d 533 (5th Cir.) · Hill v. Synder, 814 F.3d 408 (6th Cir. 2016) · Ability Center of Greater Toledo v. City of Sandusky, 385 F.3d 901 (6th Cir. 2004) · Tindall v. Wayne County Friend of the Court, 269 F.3d 533 (6th Cir. 2001)