Clark v. JPMorgan Chase Bank, N.A.
E.D. Michigan · Aug 19, 2025
What happened in this matter?
The court denied the plaintiff's motion to strike as frivolous, struck the plaintiff's reply and sur-reply, and issued an order to show cause regarding potential Rule 16(f) sanctions for costs and expenses. The court identified multiple fabricated citations and misapplied precedents, attributing these errors to the likely use of generative AI.
- Why the court cared
- The court reasoned that the plaintiff's motion was frivolous because it lacked required certifications, failed to follow local rules for concurrence, and relied on non-existent or misapplied case law. The court emphasized that under Fed. R. Civ. P. 11(b), litigants are responsible for the accuracy of their filings regardless of the tools used to generate them.
- Why it matters now
- This case illustrates the judicial response to pro se litigants using generative AI to produce filings containing fabricated citations. It reinforces that Rule 11 obligations apply to all litigants, and that courts will actively strike non-compliant filings and consider sanctions for the resulting waste of judicial and party resources.
Why this matter is tracked
In this consumer credit lawsuit, the court addressed a motion to strike filed by a pro se plaintiff. The court denied the motion as frivolous, noting that the plaintiff failed to comply with local rules regarding concurrence and signature requirements. Furthermore, the court identified multiple instances of fabricated case law and misapplied legal precedents within the plaintiff's filings. The court explicitly attributed these errors to the likely use of generative artificial intelligence, warning that such practices violate Fed. R. Civ. P. 11(b) requirements for accuracy. Consequently, the court struck the plaintiff's tardy reply and unauthorized sur-reply, and ordered the plaintiff to show cause why he should not be sanctioned for costs and expenses incurred by the defense.
This case illustrates the judicial response to pro se litigants using generative AI to produce filings containing fabricated citations. It reinforces that Rule 11 obligations apply to all litigants, and that courts will actively strike non-compliant filings and consider sanctions for the resulting waste of judicial and party resources.
Record details
What the record establishes about AI use
The court explicitly mentions the likely use of generative AI.
The court issued an order on August 19, 2025, following an in-person motion hearing held on August 18, 2025, to address the plaintiff's motion to strike affirmative defenses.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- 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).
Questions this record answers
- What happened in Clark v. JPMorgan Chase Bank, N.A.?
- The court denied the plaintiff's motion to strike as frivolous, struck the plaintiff's reply and sur-reply, and issued an order to show cause regarding potential Rule 16(f) sanctions for costs and expenses. The court identified multiple fabricated citations and misapplied precedents, attributing these errors to the likely use of generative AI.
- Why does Clark v. JPMorgan Chase Bank, N.A. matter for legal AI risk?
- This case illustrates the judicial response to pro se litigants using generative AI to produce filings containing fabricated citations. It reinforces that Rule 11 obligations apply to all litigants, and that courts will actively strike non-compliant filings and consider sanctions for the resulting waste of judicial and party resources.
- What does the public record establish about Clark v. JPMorgan Chase Bank, N.A.?
- 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.
- Which source supports this Clark v. JPMorgan Chase Bank, N.A. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.