Jane Doe, et al. v. Lincoln Consolidated Schools, et al.
E.D. Michigan · Mar 23, 2026
- Jurisdiction
- federal
- Court
- E.D. Michigan
- Record ID
- jane-doe-et-al-v-lincoln-consolidated-schools-et-al-2026-03-23
- Observed outcome
- The Court ordered Plaintiffs' counsel to reimburse Defendants for reasonable costs and fees related to the hallucinated citation.
- Known monetary consequence
- $0
Why this matter warrants attention
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.
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.
Courts now order fee-shifting for opposing counsel's wasted research on fake cites — verify or pay their bill.
Failure modes and consequences
- Fake Citations
- Civil Rights
- Trial
- Monetary
- AI attribution
- Implied
- Recorded tool
- unspecified
- Known monetary consequence
- $0
- Procedural posture
- 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.
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 characterized the citation as an AI hallucination, though the specific tool was not named.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- 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.