Incident Tracker / United States (federal)
Chirece C. v. Commissioner of Social Security, No. 25-11554 (E.D. Mich. 2026)
·United States District Court for the Eastern District of Michigan·US-FEDFine
In Michigan federal court, Magistrate Judge Elizabeth Stafford fined a Social Security claimant's lawyer $500 for AI-generated fictitious citations she admitted not checking. The same lawyer had been sanctioned in July in another case. The order warned her and Disability Law Group of heavier sanctions if uncorrected filings remain after 16 October 2026.
- Court
- United States District Court for the Eastern District of Michigan
- Date
- 2026-09-24
- Who used the AI
- Lawyer
- AI tool
- Generative AI (admitted; tool unnamed)
- Conduct
- Plaintiff's counsel in a Social Security disability appeal filed a summary-judgment brief with two fictitious citations, admitted using AI and conceded she had not verified them. The court noted the citations stayed uncorrected for almost two months after another judge had sanctioned the same lawyer, and found a non-existent case cited in a third matter.
- Outcome
- Fine
- Penalty
- US$500
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-10-05
What was fabricated or misused
- Two fictitious citations in the plaintiff's summary-judgment brief (ECF No. 10), identified in the show-cause order
- In Host v. Comm'r of Soc. Sec., No. 25-13451: "Williams v. Comm'r of Soc. Sec., 2014 WL 1406435" — does not exist; the citation belongs to an unrelated District of Maine case
- In Host: Howard v. Comm'r of Soc. Sec., 276 F.3d 235 (6th Cir. 2002), and Wages v. Sec'y of Health & Hum. Servs., 755 F.2d 495 (6th Cir. 1985), cited for rules they do not state
What the court said
“The explosive misuse of AI in court filings is serious matter that must be met with weighty consequences.”
“Rich’s firm has new internal policies in place to prevent future misrepresentations resulting from the lackadaisical use of AI. But that new policy does not obviate her responsibility to swiftly correct existing filings that include AI generated false information.”
“The Court ORDERS Ms. Rich to pay a fine of $500.00 payable to the Clerk of the Court by October 16, 2026.”
Timeline
- In Farley v. Comm'r of Soc. Sec., another judge sanctioned the same lawyer and firm for factual misrepresentations and ordered a review of pending filings.
- Court discovered the fictitious citations and ordered counsel to show cause.
- Court fined counsel $500 and warned of heavier sanctions for filings left uncorrected after 16 October 2026.
Why this case matters
The order shows a firm-wide problem across a Social Security docket: one judge ordered a caseload audit in July, and another found errors that the audit had not yet corrected, plus a fake case in a third matter. In a footnote the court also questioned the firm's statement that it uses AI to summarise medical records, citing client-confidentiality rules. A sanction in one case did not protect the lawyer from a fine in another.
Practice note
A firm that discovers AI-generated errors in one filing should audit and correct every pending brief quickly, because courts treat errors left uncorrected after notice as aggravation. Uploading unredacted client medical records to an AI tool raises confidentiality issues under Rule 1.6 that the court flagged here. Each citation in a disability brief should be opened and read before filing.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Chirece C. v. Commissioner of Social Security, No. 25-11554 (E.D. Mich. 2026)”, safelegalai.com/tracker/chirece-c-v-commissioner-social-security (accessed 2026-10-05). Data: CC BY 4.0.