Boyle, et al. v. Steven Kramer
E.D. Michigan · May 28, 2026
- Jurisdiction
- federal
- Court
- E.D. Michigan
- Record ID
- boyle-et-al-v-steven-kramer-2026-05-28
- Observed outcome
- The court overruled the plaintiffs' objections and issued a formal warning regarding the use of factitious citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to pro se plaintiffs after identifying a factitious case law citation in their filings, which the court attributed to the likely use of generative AI. The court cautioned that future submissions of factitious citations would not be tolerated and could result in sanctions, including dismissal or monetary penalties.
The court reasoned that pro se litigants have an obligation to ensure filings are scrupulously accurate and that misrepresenting the law wastes judicial resources. It cited precedent establishing that citing fake cases is sanctionable conduct.
This case illustrates judicial vigilance regarding AI-generated hallucinations in pro se filings. It reinforces that courts hold pro se litigants to accuracy standards and will issue formal warnings to deter the submission of factitious legal authority.
Failure modes and consequences
- Pro Se
- Fabricated Quotes
- Civil Rights
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- generative artificial intelligence
- Known monetary consequence
- Not recorded
- Procedural posture
- Order overruling plaintiffs' objections to a magistrate judge's order granting a motion to stay discovery.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court identified the citation as likely created by generative AI.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.