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Courts on AI / Fabricated or misquoted citations

Checks Aciek Ateny Nai v. National Asset Mortgage, LLC, et al.

United States District Court for the Western District of Michigan · Federal district courts · MI · · No. No. 1:24-cv-666 · memorandum opinion

Western District of Michigan on 2026-03-11 in Checks Aciek Ateny Nai v. National Asset Mortgage, LLC, et al. found counsel's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court discharged the show-cause issue and declined Rule 11 sanctions after reviewing the explanation for the defective authorities.

Disposition
The court discharged the show-cause issue and declined Rule 11 sanctions after reviewing the explanation for the defective authorities.
Recorded conduct
Counsel's brief contained two citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. — 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.

See, e.g., Lothamer Tax Resolution v. Kimmel, Case No. 1:25-cv-579, ECF No. 184 (W.D. Mich. December 1, 2025) (imposing Rule 11 sanctions to address “briefs . . . riddled with incorrect citations”); United States v. Hayes, 763 F. Supp. 3d 1054, 1067 (E.D. Cal. 2025) (“Citing nonexistent case law or misrepresenting the holdings of a case is making a false statement to a court.”); Dehghani v. Castro, 782 F. Supp. 3d 1051, 1057 (D.N.M. 2025) (concluding that the submission of fabricated authorities violates Rule 11); Ferris v. Amazon.com, 778 F. Supp. 3d 879, 881 (N.D. Miss. 2025) (“Mr. Ferris violated Rule 11 by submitting false citations to the Court— first, in his complaint; then, after being put on notice by Defendant, in his subsequent filings.”). Case 1:24-cv-00666-JMB-SJB ECF No. 147, PageID.882 Filed 03/11/26 Page 4 of 4 “isolated incident.” See id. As to whether Defendant NAM or its counsel have “engaged in similar conduct in other litigation,” the Court has searched for the names “National Asset Mortgage” and counsel “Matthew R. Reinhardt,” in combination with the word “sanction,” and the Court has not identified other similar sanctions proceedings. See id. The Court notes that the fabricated quotation—although material as to the applicable statute of limitations—did not “infect” the remainder of Defendant NAM’s briefing. See id. The Court further notes that both parties offered only a brief discussion of the statute of limitations, and thus Defendant NAM’s fabricated quotation did not result in the expenditure of significant “time or expense” by the parties. See id. That said, Defendant NAM and its counsel have rendered the question of whether to impose sanctions a close one by failing to correct the quotations at issue even after Plaintiff Nai expressly informed them that they had misrepresented controlling authority to the Court. The Court is also

Authorities cited in the passage: s Brief in Support of its Motion for Summary Judgment (ECF No. 117); quotation materially changed statute · s Response in Opposition to Plaintiff · Lothamer Tax Resolution v. Kimmel · United States v. Hayes · Dehghani v. Castro · Ferris v. Amazon.com · Rule 11

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