Incident Tracker / United States (federal)
Potterf v. Wessels, No. 1:26-cv-10860-MFL-PTM (E.D. Mich.)
·US District Court, Eastern District of Michigan·US-FEDWarning
In the Eastern District of Michigan, self-represented plaintiffs admitted using artificial intelligence to draft objections with fictitious or erroneous citations and an invented Supreme Court quotation. Judge Leitman denied relief based on the defective objections and warned that future papers with false, hallucinated or inaccurate citations could bring sanctions, including dismissal.
- Court
- US District Court, Eastern District of Michigan
- Date
- 2026-08-26
- Who used the AI
- Litigant in person
- AI tool
- artificial intelligence (admitted by litigants)
- Conduct
- Self-represented plaintiffs Krystal and David Potterf acknowledged using artificial intelligence to prepare objections that contained fictitious or erroneous citations, an invented Supreme Court quotation, and misread authorities. The court denied relief based on the defective objections and warned that further false or hallucinated citations may bring sanctions.
- Outcome
- Warning
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-04
What was fabricated or misused
- United States v. Sineneng-Smith, 140 S. Ct. 1575, 1579 (2020) — quoted for “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”; the quotation does not appear in the case
- United States v. Abdi, 827 F.3d 533, 538 (6th Cir. 2016) — the court said the case does not appear to exist and that 827 F.3d 533 is Van Houten v. City of Fort Worth
- Hill v. Synder, 814 F.3d 408 (6th Cir. 2016) — listed in the Index of Authorities; the court said it does not appear to exist
- Ability Center of Greater Toledo v. City of Sandusky, 385 F.3d 901, 907 (6th Cir. 2004) — cited for a reasonable-accommodation proposition about cognitive and communicative restrictions; the court said the case does not stand for that proposition
- Tindall v. Wayne County Friend of the Court, 269 F.3d 533, 539 (6th Cir. 2001) — cited for the proposition that Younger abstention was completely inapplicable; the court said Tindall held the opposite
What the court said
“As the Potterfs acknowledged during the virtual hearing on August 20, 2026, they used artificial intelligence to prepare their objections.”
“That quotation does not appear in the Sineneng-Smith case in any form.”
“The Court is convinced that the Potterfs would have caught the fictitious and/or erroneous citations if they had sufficiently reviewed the authorities in their AI-generated objections before they filed those objections.”
“There is, however, no excuse for the Potterfs’ failure to verify the accuracy of their submissions to this Court.”
Timeline
- Magistrate Judge issued R&R; six hours later plaintiffs filed 21 pages of objections.
- Virtual hearing held; plaintiffs acknowledged using AI to prepare objections.
- Court overruled objections, denied or terminated motions, and warned sanctions could include dismissal.
Why this case matters
Potterf adds a pro se federal civil-rights case tied to pending state criminal proceedings. The order is notable because the litigants admitted AI use and the court listed both non-existent cases and real cases used for invented propositions. Unlike Turgeon, the false authorities were in objections to a magistrate judge’s report, so the defect directly affected de novo review. The court stopped at a warning, but it tied any future Rule 11 violation to possible dismissal with prejudice.
Practice note
Before objecting to a magistrate judge’s report, a litigant should verify each quoted sentence in the cited opinion and confirm that the case exists in the named reporter and circuit. Objections should cite only authorities the filer has read. If AI drafted the text, every case name, quote and proposition needs a manual source check 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, “Potterf v. Wessels, No. 1:26-cv-10860-MFL-PTM (E.D. Mich.)”, safelegalai.com/tracker/potterf-v-wessels (accessed 2026-10-07). Data: CC BY 4.0.