James F. v. Commissioner of Social Security
E.D. Michigan · Jul 13, 2026
- Jurisdiction
- federal
- Court
- E.D. Michigan
- Record ID
- james-f-v-commissioner-of-social-security-2026-07-13
- Observed outcome
- The court imposed non-monetary sanctions, specifically mandatory CLE completion and a requirement to audit pending motions for similar errors.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court imposed non-monetary Rule 11 sanctions on Attorney Erin Rich and her firm for factual misrepresentations in court filings. The sanctions require the completion of specific ethics and AI-related CLE courses and a mandatory audit of all pending motions in the Eastern District of Michigan to identify and correct similar inaccuracies.
The court determined that the attorney's pattern of embellishment rose to the level of misrepresentation, violating the duty of candor under Rule 11. The court found the conduct willful, noting that the attorney failed to independently verify facts against the administrative record despite prior warnings regarding similar misconduct.
This case highlights the judicial expectation for independent verification of AI-assisted work product and the consequences of failing to supervise staff or automated tools, particularly when prior warnings regarding factual accuracy have been issued.
Failure modes and consequences
- Fake Citations
- Administrative
- Trial
- None Adjudicated
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Opinion and Order issuing Rule 11 sanctions following a show-cause order, written response, and hearing.
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
Attorney admitted firm uses AI but could not identify the specific tool.
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 a mandatory peer-review process for all briefs that includes citation-by-citation verification of facts against the source record.
- Prohibit reliance on prior work product or AI-generated summaries without independent reverification against the administrative record.
- Conduct periodic audits of pending litigation files to ensure factual accuracy and compliance with Rule 11 duties.
- Establish formal training programs for staff regarding the ethical use and supervision of AI tools in legal practice.