Joyce Barber v. Lawrence J. Morawa, MD
CA Michigan · Jun 17, 2026
- Jurisdiction
- state
- Court
- CA Michigan
- Record ID
- joyce-barber-v-lawrence-j-morawa-md-2026-06-17
- Observed outcome
- Affirmed trial court order; remanded for determination of monetary sanctions against counsel; referred counsel to the Attorney Grievance Commission.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fabricated_case_law
- Misrepresented_authority
- Hallucinated_quotes
- Failure_to_verify
- Fake Citations
- Fabricated Quotes
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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
Counsel admitted to using artificial intelligence research tools.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.