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Courts on AI / Fabricated or misquoted citations

Zlatkin v. Gladwin County, et al.

United States District Court for the Eastern District of Michigan · Federal district courts · MI · · No. No. 1:23-cv-12693 · memorandum opinion

Eastern District of Michigan on 2026-02-20 found the self-represented party's motion contained two citation defects, including Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022), ABC Corp. v..... The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's motion contained two citation defects, including Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022), ABC Corp. v. XYZ Inc., 123 F.3d 456 (6th Cir. 2019) and Wells v. UPS Airlines, involving nonexistent authorities, mischaracterized... — 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.

sever her claim from Sharon’s. Id. at PageID.2357–58. Fourth, she argues that Judge Morris erred in not recusing herself. Id. at PageID.2358–59. In so doing, she cites a case that does not exist— “Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022).” 3 Id. at PageID.2359. Fifth, Peggy asserts that the R&R erred by denying her Motion for Summary Judgment as premature. Id. In that Objection, she critiques the R&R for failing to cite or analyze 3 To be sure, there is a decision named Wells v. United Parcel Serv. Airlines, 688 F. Supp. 3d 567, 570 (W.D. Ky. 2023). But that case addressed no issue of recusal, was decided in a different year than the fake authority Plaintiff invokes, and appears at a different reporter citation than the one she provides. In short, it is not the case Plaintiff purports to cite. -9- Case 1:23-cv-12693-TLL-PTM ECF No. 164, PageID.2714 Filed 02/20/26 Page 10 of 12 a “binding” case. Id. at PageID.2360. But like before, the “binding” case that she cites, “ABC Corp. v. XYZ Inc., 123 F.3d 456 (6th Cir. 2019),” does not exist. Id. If a party properly objects, then “[t]he district judge must determine de novo” the part of the R&R to which the objection pertains. FED. R. CIV. P. 72(b)(3). When reviewing an R&R de novo, courts must review at least the evidence that the parties presented to the magistrate judge. See Hill v. Duriron Co., 656 F.2d 1208, 1215 (6th Cir. 1981). After reviewing the evidence, the

Authorities cited in the passage: Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022) · s recusal argument. || Fabricated: Case Law | Plaintiff cited · Wells v. UPS Airlines · Wells v. United Parcel Serv. Airlines · ABC Corp. v. XYZ Inc · See Hill v. Duriron Co

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