Jane Doe, et al. v. Lincoln Consolidated Schools, et al.
E.D. Michigan · Mar 23, 2026
What happened in this matter?
The Court sanctioned Plaintiffs' counsel for including an unverified, AI-hallucinated case citation in their brief. The judge ordered counsel to reimburse Defendants for the costs and fees associated with researching the non-existent authority and bringing the error to the Court's attention.
- Why the court cared
- The Court found that the cited case did not exist and that the four cases provided by counsel to explain the 'Frankenstein' citation did not support the proposition for which they were cited. The Court concluded that counsel failed to verify the validity of the citation or ensure it supported their legal arguments.
- Why it matters now
- Courts now order fee-shifting for opposing counsel's wasted research on fake cites — verify or pay their bill.
Why this matter is tracked
In a civil rights action, Plaintiffs' counsel submitted a brief containing a non-existent case citation, 'Doe v. Univ. of Mich., No. 18-11914, 2019 WL 11793988 (E.D. Mich., Aug. 6, 2019).' The Court was unable to locate the authority and rejected counsel's explanation that the citation resulted from an inadvertent combination of multiple cases. The Court characterized the error as an 'AI hallucination' that counsel failed to verify. Consequently, the Court ordered Plaintiffs' counsel, Delaporte Lynch, PLLC, to reimburse Defendants for the reasonable costs and fees incurred in researching the hallucinated citation and raising the issue before the Court. The sanction was imposed specifically on counsel, not the Plaintiffs.
Courts now order fee-shifting for opposing counsel's wasted research on fake cites — verify or pay their bill.
Record details
What the record establishes about AI use
The Court characterized the citation as an AI hallucination, though the specific tool was not named.
The Court issued an Opinion and Order on cross-motions for summary judgment, granting in part and denying in part Defendants' motion and denying Plaintiffs' motion, while simultaneously imposing a monetary sanction on Plaintiffs' counsel for the inclusion of a hallucinated citation.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- 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.
Questions this record answers
- What happened in Jane Doe, et al. v. Lincoln Consolidated Schools, et al.?
- The Court sanctioned Plaintiffs' counsel for including an unverified, AI-hallucinated case citation in their brief. The judge ordered counsel to reimburse Defendants for the costs and fees associated with researching the non-existent authority and bringing the error to the Court's attention.
- Why does Jane Doe, et al. v. Lincoln Consolidated Schools, et al. matter for legal AI risk?
- Courts now order fee-shifting for opposing counsel's wasted research on fake cites — verify or pay their bill.
- What does the public record establish about Jane Doe, et al. v. Lincoln Consolidated Schools, et al.?
- 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 Jane Doe, et al. v. Lincoln Consolidated Schools, et al. 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.