Jonathan David Deak v. Mike Schuitema, et al.
W.D. Michigan · Jun 18, 2026 · Paul L. Maloney
- Jurisdiction
- federal
- Court
- W.D. Michigan
- Record ID
- jonathan-david-deak-v-mike-schuitema-et-al-2026-06-18
- Observed outcome
- The court adopted the Magistrate Judge's report and recommendation and dismissed the plaintiff's complaint with prejudice.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court dismissed the plaintiff's complaint with prejudice after finding his legal claims frivolous and unsupported by law. The court explicitly identified a false quotation attributed to Brown v. Matauszak, noting it was likely an AI-generated hallucination, and flagged other unverified citations in the plaintiff's filings as likely AI-generated.
The court reasoned that the plaintiff's core argument regarding a right to counsel in civil proceedings was unsupported by legal authority. Regarding the false quotation, the court noted the sentence did not exist in the cited opinion and questioned if it was an AI hallucination, while also noting the plaintiff's filings contained multiple unverified citations likely generated by AI.
This case illustrates judicial scrutiny of pro se filings containing AI-generated hallucinations and unverified citations. It highlights the court's role in identifying and documenting such errors in the official record, even when no formal sanctions are imposed.
Failure modes and consequences
- Hallucinated_case_law
- Fabricated_quotes
- Unverified_citations
- Pro Se
- Fake Citations
- Fabricated Quotes
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court reviewed the Magistrate Judge's Report and Recommendation (R&R) de novo following the plaintiff's objections and issued an Opinion and Order adopting the R&R and dismissing the complaint.
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 referenced AI tools used by a party or counsel.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- 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.