Clark v. JPMorgan Chase Bank, N.A.
E.D. Michigan · Aug 19, 2025
- Jurisdiction
- federal
- Court
- E.D. Michigan
- Record ID
- clark-v-jpmorgan-chase-bank-na-2025-08-19
- Observed outcome
- Plaintiff's motion to strike was denied as frivolous; plaintiff's reply and sur-reply were struck; plaintiff was ordered to show cause regarding potential sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Hallucinated_case_law
- Misrepresented_precedent
- Procedural_noncompliance
- Pro Se
- Fake Citations
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- generative artificial intelligence
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 explicitly mentions the likely use of 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
- Implement mandatory verification protocols for all case citations and legal authorities before submission.
- Ensure all filings strictly adhere to local rules regarding concurrence, signature requirements, and authorized briefing schedules.
- Establish internal review processes to detect and correct AI-generated hallucinations in legal research.
- Monitor docket activity for show-cause orders or sanctions related to the use of unverified AI-generated content.