Shaun Fleck v. Del-One Federal Credit Union

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

case” and the only source on Westlaw that includes the quote that Fleck attributes to the non-existent case is Fleck’s response in this case. Cf. Whiting v. City of Athens, No. 24-5918, --- F.4th ---- , 2026 WL 710568, at *1, *3, *10-13 (6th Cir. Mar. 13, 2026) (sanctioning lawyers for submitting briefing that “cited non-existent cases[] and cited cases for propositions of law that they did not even discuss, much less support,” explaining that the “appeal [was] frivolous as argued because [the lawyers] submitted fake cases, and inventing case law is a misrepresentation of law,” and providing examples that the Sixth Circuit was unable to locate, citations that did “not generate a case,” and an instance in which the “only source on Westlaw” was a lawyer’s “briefing in th[e] case”). It is also important to consider “when AI is used to prepare a brief, ‘AI hallucinations are more likely to occur when there are little to no existing authorities available that clearly satisfy the user’s request—such as, for example, when a [litigant] asks a generative AI tool to supply a citation for an unsupported principle of law.’” Id. at