Joyce Barber v. Lawrence J. Morawa, MD
CA Michigan · Jun 17, 2026
What happened in this matter?
The Michigan Court of Appeals sanctioned plaintiff's counsel for submitting fabricated case citations and misrepresented legal authorities generated by AI. The court remanded the case to the trial court to determine the amount of reasonable attorney fees and expenses to be paid by counsel personally and referred the attorney to the Attorney Grievance Commission for investigation.
- Why the court cared
- The court reasoned that counsel's repeated submission of fabricated and unsupported authority violated the duty of reasonable inquiry under MCR 1.109(E)(5) and MCR 7.216(C)(1)(b). The court emphasized that an attorney's signature on a filing certifies that the document is well-grounded in fact and warranted by existing law after reasonable inquiry, and that subjective good faith is irrelevant to this objective standard. The court noted that counsel had been alerted to the deficiencies multiple times but failed to correct them, demonstrating gross disregard for the requirements of fair presentation.
- Why it matters now
- This case establishes that Michigan courts will impose mandatory sanctions for AI-generated hallucinations in filings. It underscores that counsel's duty of reasonable inquiry is non-delegable to AI tools and that repeated failures, even if attributed to 'innocent' mistakes, will result in personal liability for opposing party's fees and disciplinary referral.
Why this matter is tracked
In a medical malpractice appeal, the Michigan Court of Appeals affirmed the denial of a new trial but sanctioned plaintiff's counsel for repeated submission of fabricated and unsupported legal authority. Counsel relied on generative AI to produce nonexistent case citations and misrepresented real authorities, including attributing quotations to cases that did not contain them. Despite being alerted to these deficiencies by opposing counsel in the trial court, the attorney continued to submit hallucinated citations and unsupported propositions in appellate filings. The court held that this conduct violated the duty of reasonable inquiry under MCR 1.109(E)(5) and MCR 7.216(C)(1)(b). The court remanded the case for a determination of actual damages and attorney fees to be paid by counsel personally and referred the matter to the Attorney Grievance Commission.
This case establishes that Michigan courts will impose mandatory sanctions for AI-generated hallucinations in filings. It underscores that counsel's duty of reasonable inquiry is non-delegable to AI tools and that repeated failures, even if attributed to 'innocent' mistakes, will result in personal liability for opposing party's fees and disciplinary referral.
Record details
What the record establishes about AI use
Counsel admitted to using artificial intelligence research tools.
Appellate review of a trial court order denying a motion for a new trial or evidentiary hearing, with a concurrent finding of sanctionable conduct by counsel.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Counsel attributed quoted language about "extraneous prejudicial information" and "outside influence" to Miller although those phrases do not appear in Miller (they derive from MRE 606(b)(2)).
- Misrepresented: Case Law | Counsel cited People v. Budzyn for a standard of review it does not state, using the case to support propositions it does not contain.
- Fabricated: Case Law | Counsel cited a nonexistent opinion in a motion for a protective order.
- Fabricated: Case Law | Counsel cited a nonexistent criminal appellate opinion in the new-trial motion.
- Fabricated: Case Law | Counsel cited a nonexistent criminal appellate opinion in the new-trial motion.
- Fabricated: Case Law | Counsel cited a nonexistent appellate case in the appellate brief.
Questions this record answers
- What happened in Joyce Barber v. Lawrence J. Morawa, MD?
- The Michigan Court of Appeals sanctioned plaintiff's counsel for submitting fabricated case citations and misrepresented legal authorities generated by AI. The court remanded the case to the trial court to determine the amount of reasonable attorney fees and expenses to be paid by counsel personally and referred the attorney to the Attorney Grievance Commission for investigation.
- Why does Joyce Barber v. Lawrence J. Morawa, MD matter for legal AI risk?
- This case establishes that Michigan courts will impose mandatory sanctions for AI-generated hallucinations in filings. It underscores that counsel's duty of reasonable inquiry is non-delegable to AI tools and that repeated failures, even if attributed to 'innocent' mistakes, will result in personal liability for opposing party's fees and disciplinary referral.
- What does the public record establish about Joyce Barber v. Lawrence J. Morawa, MD?
- 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 Joyce Barber v. Lawrence J. Morawa, MD 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.