Lothamer Tax Resolution, Inc. v. Paul Kimmel (2)
W.D. Michigan · Dec 1, 2025
What happened in this matter?
The court imposed a $2,900 monetary sanction on a pro se litigant for violating Rule 11 by repeatedly submitting filings containing fabricated and misrepresented legal authorities. The court rejected the litigant's claim that the errors were merely stylistic, finding the conduct an abuse of the judicial system.
- Why the court cared
- False Quotes: Case Law | Court found the quoted language attributed to Mickey v. Zeidler Tool & Die Co. does not appear in the cited opinion. || Fabricated: Case Law | Court determined Stefanski v. City of Center Line (504 Mich. 877 (2019)) does not exist at that citation and the reference appears fabricated. || Misrepresented: Case Law | Kaufman & Payton citation was used to assert a specific legal proposition the Court found the case does not support. || Misrepresented: Case Law | Court noted Chandler was cited for a point the opinion does not discuss; the citation was misapplied. || Misrepresented: Case Law | United States v. Garber was cited as if addressing professional responsibility, but the opinion is a tax-evasion appeal and does not support the asserted proposition. || False Quotes: Case Law | Court found the quoted language attributed to Shallal v. Catholic Social Services is not present in that opinion. || Misrepresented: Case Law | Wurtz was cited for propositions about knowledge and causation that the Court said Wurtz does not address. || Fabricated: Case Law | Pettigrew citation does not correspond to a defamation case and the named decision does not appear to exist at that citation (fabricated/interstitial miscitation). || False Quotes: Case Law | Court found the quote attributed to U.S. ex rel. Marlar does not appear in that Sixth Circuit opinion. || False Quotes: Case Law | Riverview was cited for a specific maxim about pleading and amendment that the Court concluded Riverview does not contain. || Misrepresented: Case Law | Court found the Olitkowski and Wolverine citations do not contain the equitable-restitution language the defendant quoted or were misapplied. || Fabricated: Case Law | Wirsing citation appears to be fabricated or is an interstitial miscitation; the Court found no supporting authority at the cited source.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in W.D. Michigan, with the listed outcome: Monetary Sanction.
Why this matter is tracked
The U.S. District Court for the Western District of Michigan sanctioned a pro se defendant, Paul Kimmel, for repeatedly filing briefs containing fictitious and misrepresented legal citations. Despite a prior warning, Kimmel submitted filings with dozens of errors, including fabricated cases and false quotes. Kimmel denied using generative AI, attributing the errors to poor research practices and reliance on secondary sources. The Court found this explanation inadequate and not credible, concluding that the filings violated Rule 11 of the Federal Rules of Civil Procedure. The Court imposed a monetary sanction of $2,900, calculated at $100 per false citation, and warned that future violations would result in increased penalties.
This record documents a Pro Se Litigant filing issue in W.D. Michigan, with the listed outcome: Monetary Sanction.
Record details
What the record establishes about AI use
Court noted errors are hallmarks of AI-generated content.
Order imposing Rule 11 monetary sanctions following a show cause order regarding misleading and fictitious citations in pro se filings.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
12 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Court found the quoted language attributed to Mickey v. Zeidler Tool & Die Co. does not appear in the cited opinion.
- Fabricated: Case Law | Court determined Stefanski v. City of Center Line (504 Mich. 877 (2019)) does not exist at that citation and the reference appears fabricated.
- Misrepresented: Case Law | Kaufman & Payton citation was used to assert a specific legal proposition the Court found the case does not support.
- Misrepresented: Case Law | Court noted Chandler was cited for a point the opinion does not discuss; the citation was misapplied.
- Misrepresented: Case Law | United States v. Garber was cited as if addressing professional responsibility, but the opinion is a tax-evasion appeal and does not support the asserted proposition.
- False Quotes: Case Law | Court found the quoted language attributed to Shallal v. Catholic Social Services is not present in that opinion.
- Misrepresented: Case Law | Wurtz was cited for propositions about knowledge and causation that the Court said Wurtz does not address.
- Fabricated: Case Law | Pettigrew citation does not correspond to a defamation case and the named decision does not appear to exist at that citation (fabricated/interstitial miscitation).
Show 4 additional discrepancies
- False Quotes: Case Law | Court found the quote attributed to U.S. ex rel. Marlar does not appear in that Sixth Circuit opinion.
- False Quotes: Case Law | Riverview was cited for a specific maxim about pleading and amendment that the Court concluded Riverview does not contain.
- Misrepresented: Case Law | Court found the Olitkowski and Wolverine citations do not contain the equitable-restitution language the defendant quoted or were misapplied.
- Fabricated: Case Law | Wirsing citation appears to be fabricated or is an interstitial miscitation; the Court found no supporting authority at the cited source.
Questions this record answers
- What happened in Lothamer Tax Resolution, Inc. v. Paul Kimmel (2)?
- The court imposed a $2,900 monetary sanction on a pro se litigant for violating Rule 11 by repeatedly submitting filings containing fabricated and misrepresented legal authorities. The court rejected the litigant's claim that the errors were merely stylistic, finding the conduct an abuse of the judicial system.
- Why does Lothamer Tax Resolution, Inc. v. Paul Kimmel (2) matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in W.D. Michigan, with the listed outcome: Monetary Sanction.
- What does the public record establish about Lothamer Tax Resolution, Inc. v. Paul Kimmel (2)?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Lothamer Tax Resolution, Inc. v. Paul Kimmel (2) 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.