Barber v. Morawa

AI hallucination case: Barber v. Morawa

Court: CA MichiganTool: Claude, ChatGPT, Westlaw, Lexis

Court recordHarms: Hallucination in legal filingsOfficial source · courts.michigan.gov ↗

27 MAR 2026 · Court Case

Patrick C. Shaltry, I v. Brent Benzing, et al.

False Quotes: Case Law | Plaintiff attributed the sentence "A conviction is not final until the completion of the direct appeal." to People v. Swafford; the Court found the quote does not appear in the opinion and noted cited passages contradict the proposition. || False Quotes: Case Law | Plaintiff attributed the sentence "A judgment is not final while an appeal of right remains pending." to People v. Kennedy; the Court found the quote does not appear in the opinion. || Fabricated: Case Law | Plaintiff cited "People v. Smith, 489 Mich. 292, 311 (2011)" for the proposition "A conviction pending on direct appeal is not a final adjudication." The Court was unable to locate the cited case and treated the citation as fabricated. || Fabricated: Case Law | Plaintiff cited "Savin v. City of Cleveland, 2022 WL 3715087 (6th Cir. 2022)"; the Court found the Westlaw citation pointed to an unrelated brief and could not locate a case by that name, indicating a likely mis-citation or fabrication.

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

27 MAR 2026 · Court Case

Pizzimenti v. City of Detroit, et al.

Misrepresented: Case Law | Plaintiff cited Opulent Life Church, 697 F.3d 279 in support of fines/Eighth Amendment/retaliation arguments, but the court noted that Opulent Life Church does not involve fines nor those claims and was thus misapplied. || Fabricated: Case Law | Plaintiff cited 'Williams v. City of Cleveland, No. 1:18-CV-2911, 2019 WL 5485190 (N.D. Ohio Oct. 25, 2019),' which the court and R&R found does not exist in Westlaw or under that docket. || False Quotes: Case Law | Plaintiff quoted language attributed to Jensen v. Utah Cnty., 2025 WL 2208257 (D. Utah Aug. 4, 2025), but the quoted passage does not appear in that opinion. || Fabricated: Case Law | Complaint referenced 'Thaxton v. City of Pontiac, No. 298862, 2011 WL 522951 (Mich. Ct. App. Feb. 15, 2011),' a citation the court says does not exist. || Fabricated: Case Law | Complaint referenced 'Smith v. State, 26 N.E.3d 1167 (Ind. 2015),' which the court was unable to locate or identify as relevant.

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

23 MAR 2026 · Court Case

Jane Doe, et al. v. Lincoln Consolidated Schools, et al.

Fabricated: Case Law | Plaintiffs cited a non-existent case string "Doe v. Univ. of Mich., No. 18-11914, 2019 WL 11793988, at *8 (E.D. Mich., Aug. 6, 2019)"; the Court could not locate the authority, characterized it as an AI‑hallucinated/"Frankenstein" citation, and ordered counsel to reimburse defendants for research costs.

Court: E.D. MichiganParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

23 MAR 2026 · Court Case

Gregory Hardy v. K. Jones, et al.

False Quotes: Case Law | Plaintiff attributed the phrase "reason to believe" to Berndt v. Tennessee; the court found the Berndt opinion does not contain that language nor address the claimed issue. || False Quotes: Case Law | Plaintiff attributed the phrase "amateur psychologist" to United States v. Frazier; the court found that phrase does not appear in Frazier and the criminal case does not address the motion's issues.

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

11 MAR 2026 · Court Case

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

Fabricated: Legal Norm | Counsel for NAM included a fabricated quotation altering the language of 12 U.S.C. § 2614 in NAM's Brief in Support of its Motion for Summary Judgment (ECF No. 117); quotation materially changed statute's plain meaning. || Fabricated: Legal Norm | Same fabricated quotation of 12 U.S.C. § 2614 repeated in NAM's Response in Opposition to Plaintiff's Motion for Partial Summary Judgment (ECF No. 132); Plaintiff had previously notified NAM of the inaccuracy.

Court: W.D. MichiganParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: W.D. Michigan

02 MAR 2026 · Court Case

Hardy v. Whitaker

Fabricated: Case Law | Plaintiff's MSJ included the citation 'Patel v. City of Ferndale, 308 F.3d 511, 517 (6th Cir. 2002)'; the court identified it as a fabricated/phantom case likely produced by generative AI and flagged it as a hallucination. || Fabricated: Case Law | Plaintiff's MSJ included the citation 'Thompson v. City of Lebanon, 813 F.3d 318, 323 (6th Cir. 2016)'; the court identified it as a fabricated citation likely resulting from AI and noted it among fake citations. || Fabricated: Case Law | Plaintiff's MSJ included the citation 'Spurlock v. Satterfield, 167 F.3d 915 (5th Cir. 1999)'; the court listed this as one of several fake citations and suspected AI-generated hallucination. || Fabricated: Case Law | Plaintiff's MSJ included the citation 'Wesley v. Rigney, 860 F.3d 931 (6th Cir. 2017)'; the court characterized this as a fake citation likely produced by generative AI and cited it as an example of 'phantom cases.'

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

20 FEB 2026 · Court Case

Zlatkin v. Gladwin County, et al.

Fabricated: Case Law | Plaintiff cited 'Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022)'; the Court determined no such decision exists and noted a different similarly titled decision does not support plaintiff's recusal argument. || Fabricated: Case Law | Plaintiff cited 'ABC Corp. v. XYZ Inc., 123 F.3d 456 (6th Cir. 2019)'; the Court found that citation to be nonexistent and not a valid binding authority.

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

28 JAN 2026 · Court Case

Gregory Hardy v. Genesee County Community Action Resource Department, et al.

Fabricated: Case Law | Plaintiff cited this case in his brief; the court identified the citation as fake and noted it among AI-generated phantom cases in the filing. || Fabricated: Case Law | Plaintiff cited this opinion; the court flagged the citation as a fake/invalid citation in the filing and linked it to suspected AI usage. || Fabricated: Case Law | Plaintiff relied on this purported Sixth Circuit decision in his motion to compel; the court identified the citation as fake and noted it as part of the problematic filings. || Fabricated: Case Law | Plaintiff cited this decision in his production-motion brief; the court characterized it as a fake citation appearing in the plaintiff's filings and tied to suspected generative-AI use.

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

16 JAN 2026 · Court Case

Rev. Heidi Grossman Lepp v. Conrad Mallett, Jr., et al.

Misrepresented: Case Law | The AI report asserted that Church of the Lukumi Babalu Aye v. City of Hialeah supports the plaintiff's standing to assert her church's rights; the court noted Lukumi does not discuss standing. || Fabricated: Case Law | The AI report contained various incorrect or nonexistent case citations and factitious references; the court described the Report as unreliable and declined to consider it.

Court: E.D. MichiganParty: Pro Se LitigantTool: ChatGPT

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

16 JAN 2026 · Court Case

Tiffany K. v. Commissioner of Social Security

Fabricated: Case Law | Counsel's brief included a non-existent case citation 'Fleck v. Comm’r of Soc. Sec.'; the Court identified it as a 'phantom' citation likely generated by AI and admonished counsel.

Court: E.D. MichiganParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

07 JAN 2026 · Court Case

Kamps v. British Crown Corporation, et al.

False Quotes: Case Law | Plaintiff attributed a fabricated quotation to Penhallow v. Doane's Administrators, asserting governments are "abstractions" that cannot interact with "the tangible"; the Court identified the quote as fake and not in the 1795 prize case.

Court: W.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: W.D. Michigan

01 JAN 2026 · Law / Act

Michigan HB 4668

Michigan legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Secondary evidenceGenerative AI ·Data Privacy & ProtectionIssuing institution: Issuing authority not identified

29 DEC 2025 · Court Case

Rachel Jones v. Experian Information Solutions

Misrepresented: Case Law | Plaintiff cited Great Earth Companies, Inc. v. Simons, 288 F.3d 878, 889 (6th Cir. 2002) as supporting the proposition that discovery is required to determine arbitrability; the Court found Great Earth does not address discovery and flagged the misstatement as possibly AI-related.

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

19 DEC 2025 · Court Case

Patrick Joseph Groulx v CSL Limited

Fabricated: Case Law | Appellant's brief included citation to a non-existent case; court found it to be a fabricated case citation and relied on this as part of basis to dismiss the appeal. || Fabricated: Case Law | Appellant's brief included a second citation to a non-existent case; court treated this as another fabricated citation contributing to dismissal.

Court: CA MichiganParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: CA Michigan

02 DEC 2025 · Court Case

Jarrus et al. v. Governor of Michigan et al.

Misrepresented: Case Law | Plaintiffs cited Krupski for the proposition that relation-back amendment is mandatory; court found Krupski does not establish that mandatory rule and the plaintiffs overstated the case's holding. || Misrepresented: Case Law | Plaintiffs cited Heller to claim temporary loss of Second Amendment rights is irreparable harm; court held Heller does not state that and plaintiffs improperly extended Elrod (a First Amendment case) to the Second Amendment. || Outdated Advice: Repealed Law | Plaintiffs relied on Oppenheimer for scope of discovery under Rule 26; court noted Oppenheimer has been superseded by statute and reliance on it was misplaced.

Court: E.D. MichiganParty: Pro Se LitigantTool: ChatGPT

Fine: 1

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

01 DEC 2025 · Court Case

Lothamer Tax Resolution, Inc. v. Paul Kimmel (2)

False Quotes: Case Law | Court found the quoted language attributed to Mickey v. Zeidler Tool & Die Co. does not appear in the cited opinion. || Fabricated: Case Law | Court determined Stefanski v. City of Center Line (504 Mich. 877 (2019)) does not exist at that citation and the reference appears fabricated. || Misrepresented: Case Law | Kaufman & Payton citation was used to assert a specific legal proposition the Court found the case does not support. || Misrepresented: Case Law | Court noted Chandler was cited for a point the opinion does not discuss; the citation was misapplied. || Misrepresented: Case Law | United States v. Garber was cited as if addressing professional responsibility, but the opinion is a tax-evasion appeal and does not support the asserted proposition. || False Quotes: Case Law | Court found the quoted language attributed to Shallal v. Catholic Social Services is not present in that opinion. || Misrepresented: Case Law | Wurtz was cited for propositions about knowledge and causation that the Court said Wurtz does not address. || Fabricated: Case Law | Pettigrew citation does not correspond to a defamation case and the named decision does not appear to exist at that citation (fabricated/interstitial miscitation). || False Quotes: Case Law | Court found the quote attributed to U.S. ex rel. Marlar does not appear in that Sixth Circuit opinion. || False Quotes: Case Law | Riverview was cited for a specific maxim about pleading and amendment that the Court concluded Riverview does not contain. || Misrepresented: Case Law | Court found the Olitkowski and Wolverine citations do not contain the equitable-restitution language the defendant quoted or were misapplied. || Fabricated: Case Law | Wirsing citation appears to be fabricated or is an interstitial miscitation; the Court found no supporting authority at the cited source.

Court: W.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: W.D. Michigan

10 NOV 2025 · Court Case

Marques Johnson v. Capital One Financial Corporation

False Quotes: Case Law | Plaintiff cited Cohen v. Cap. One Funding, LLC and attributed a quotation—"Receivables are pooled and sold monthly."—to that opinion and misidentified the issuing court; the magistrate judge found the alleged quote does not appear in the Cohen decision and flagged it as likely an AI-generated hallucination.

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

06 NOV 2025 · Court Case

David Angel Sifuentes, III v. Christian Brothers Automotive

Fabricated: Case Law | Plaintiff relied on a nonexistent case citation; court noted 'Bolin v. Story, 225 F.3d 1234, 1239 (6th Cir. 2000)' does not exist and had been previously warned.

Court: W.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: W.D. Michigan

30 OCT 2025 · Court Case

Warner v. Gilbarco, Inc.

Fabricated: Case Law | Plaintiff twice cited 'Smith v. Dow Chem. Co., 166 F.R.D. 1, 2 (E.D. Mich. 1996)' to argue depositions should not proceed; the court found this a 'phantom' citation and noted the actual existing opinion is Hamm v. Nasatka Barriers Inc., 166 F.R.D. 1 (D.D.C. 1996), which does not mention depositions.

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

19 SEP 2025 · Court Case

Ali v. IT People Corporation

False Quotes: Case Law | Plaintiff falsely represented that Union Planters v. L&J Dev. Co., 115 F.3d 378 (6th Cir. 1997) contained language holding that Rule 11 sanctions are “reserved for exceptional circumstances”; court found this a false quotation and pivotal misrepresentation. || Misrepresented: Legal Norm | Plaintiff falsely stated that Michigan's Bullard-Plawecki Employee Right to Know Act requires employers to produce personnel records within 10 business days; court found this statutory deadline claim to be a misrepresentation of the law. || Fabricated: Legal Norm | Plaintiff cited Michigan Admin. Code R 408.8004, a regulatory provision that the court determined does not exist (a phantom or fabricated regulatory citation); plaintiff admitted the citation was nonexistent.

Court: E.D. MichiganParty: Pro Se Litigant

Fine: 600 USD

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

29 AUG 2025 · Court Case

Lothamer Tax Resolution, Inc. v. Paul Kimmel (1)

Fabricated: Case Law | Court determined the citation to Baker Hughes Inc. v. S&S Chem., LLC (No. 2:21-cv-2611, 2022 WL 1591563) could not be located at the provided citation and treated it as a fictitious authority. || Misrepresented: Case Law | Court concluded Kimmel mischaracterized or quoted inaccurately from Shane Grp. v. Blue Cross (825 F.3d 299, 305 (6th Cir. 2016)), citing language not found in the decision. || Fabricated: Case Law | Court noted the citation to Hall v. Hall, 584 U.S. 147 (2018) was cited at a location that could not be verified and flagged it among other suspect citations. || False Quotes: Case Law | Court observed that language Kimmel attributes to FormFactor, Inc. v. Micro-Probe, Inc. (No. 10-3095, 2012 WL 2061520) does not appear in that opinion, i.e., a false quotation/misattribution. || Fabricated: Case Law | Court found the cited PFK Co. v. Protective Technologies, Inc., 624 F. Supp. 2d 802 (S.D. Ind. 2008) could not be located at the provided citation and treated it as a fabricated authority.

Court: W.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: W.D. Michigan

19 AUG 2025 · Court Case

Clark v. JPMorgan Chase Bank, N.A.

Fabricated: Case Law | Court found the citation 'United States v. Provident Bank, 2021 WL 1985046, at 2 (E.D. Mich. May 18, 2021)' cannot be located and likely does not exist. || Fabricated: Case Law | Court identified 'Gibson v. Rosati, 2017 WL 1155765 (N.D.N.Y. Mar. 27, 2017)' as a citation that does not appear to exist or is not retrievable. || Fabricated: Case Law | Court noted 'Jones v. TransUnion LLC, 2022 WL 407915 (E.D. Mich. Feb. 10, 2022)' as a referenced citation that could not be located and may be fictitious. || Misrepresented: Case Law | Court observed Beaudry v. TeleCheck Servs., Inc., 579 F.3d 702 (6th Cir. 2009) was cited by the plaintiff for a principle the case does not address (misapplied precedent).

Court: E.D. MichiganParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

28 JUL 2025 · Court Case

Seither & Cherry Quad Cities v. Oakland Automation

False Quotes: Case Law || Misrepresented: Case Law

Court: E.D. MichiganParty: Lawyer

Fine: 1485 USD

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

24 JUN 2025 · Working Paper

Michigan House Bill 4668 (Artificial Intelligence Safety and Security Transparency Act)

Requires large developers of artificial intelligence (AI) models in Michigan to implement comprehensive safety and security protocols to manage critical risks associated with foundation models, including potential large-scale harm or damage exceeding $1 billion. Defines "large developers" as those using a substantial amount of computing power and specifies obligations to document and publish safety protocols, conduct regular risk assessments, and submit to annual third-party audits. Establi...

Official materialNational StrategyOfficial source · legislature.mi.gov ↗

21 MAR 2025 · Court Case

Loyer v. Wayne County Michigan

Fabricated: Case Law | Plaintiff's counsel included AI-generated bogus legal citations in the response brief; the Court admonished counsel and ordered attendance at an ethics seminar. || Misrepresented: Exhibits & Submissions | Plaintiff's brief asserted Loyer reported psychiatric illness, daily meth use, severe withdrawal with hallucinations, and was uncooperative/anxious/angry; the Court found the cited medical records show the opposite (denials and 'unremarkable'/'appropriate').

Court: E.D. MichiganParty: Lawyer

⚠ Professional sanction imposed

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. Michigan

30 JUL 2024 · Law / Act

Michigan House Bill 5507

Allocates $500,000 for a statewide AI research hub, enhancing expertise on responsible AI use in schools. Supports virtual education, best practices, and policy recommendations. Fosters innovation in instructional technology and virtual learning models for Michigan's education system.

Primary legal sourceFinancial Services ·Education ·Health & Life Sciences ·+2Official source · legislature.mi.gov ↗

30 NOV 2023 · Law / Act

Michigan House Bill 5141

Requires political advertisements generated substantially by AI to include disclaimers indicating AI involvement. Mandates specific formatting for AI disclaimers in graphic, audio, and video ads. Establishes fines for non-compliance and outlines exemptions for certain media and platforms.

Primary legal sourceFinancial Services ·Education ·Health & Life Sciences ·+2Official source · legislature.mi.gov ↗

30 NOV 2023 · Other

Michigan HB 5143

Defines artificial intelligence as machine-based systems capable of influencing environments via predictions, recommendations, or decisions using both machine and human inputs. Specifies conditions for the definition's applicability contingent on the enactment of related legislation.

Official materialFinancial Services ·Education ·Health & Life Sciences ·+2Official source · legislature.mi.gov ↗

12 JAN 2023 · Law / Act

Michigan House Bill 5144 of 2023 (Election Law)

Prohibits distributing AI-generated deceptive media within 90 days before elections if intended to harm a candidate or deceive voters. Requires disclaimers for exceptions. Penalizes violations with fines and imprisonment. Allows injunctive relief by affected parties or the attorney general.

Primary legal sourceFinancial Services ·Education ·Health & Life Sciences ·+2Official source · legislature.mi.gov ↗