Lothamer Tax Resolution, Inc. v. Paul Kimmel (2)
W.D. Michigan · Dec 1, 2025
- Jurisdiction
- federal
- Court
- W.D. Michigan
- Record ID
- lothamer-tax-resolution-inc-v-paul-kimmel-2-2025-12-01
- Observed outcome
- The court imposed a monetary sanction of $2,900, payable to the Clerk of Court, for 29 identified instances of false or misrepresented citations.
- Known monetary consequence
- $2,900
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in W.D. Michigan, with the listed outcome: Monetary Sanction.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Employment
- Trial
- AI attribution
- Implied
- Recorded tool
- Generative AI (implied/unspecified)
- Known monetary consequence
- $2,900
- Procedural posture
- Order imposing Rule 11 monetary sanctions following a show cause order regarding misleading and fictitious citations in pro se filings.
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
Court noted errors are hallmarks of AI-generated content.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.
- Escalate and correct a suspect filing promptly, with a documented response.