Patrick C. Shaltry, I v. Brent Benzing, et al.
E.D. Michigan · Mar 27, 2026
What happened in this matter?
The court issued a formal warning to the pro se plaintiff regarding the inclusion of fabricated citations and false quotations in his filings. The court explicitly cautioned that further misrepresentations of fact or law would result in a recommendation for sanctions under Federal Rule of Civil Procedure 11.
- Why the court cared
- The court reasoned that the plaintiff is responsible for the accuracy of all filings under Rule 11, regardless of whether the content was generated by AI or the plaintiff's pro se status. The court found the cited authorities were either non-existent or did not support the propositions for which they were cited.
- Why it matters now
- Quoted passages contradicting the cited case's holding are red flags — read the opinion, not just the pincite.
Why this matter is tracked
In a civil rights action, the pro se plaintiff submitted multiple filings containing fabricated case law citations and false quotations, including misattributed language in People v. Swafford and People v. Kennedy, and a non-existent citation to People v. Smith. The court identified these as likely AI-generated hallucinations. The court denied the plaintiff's motions for sanctions against defendants, noting that the plaintiff's legal premise regarding his conviction status was incorrect. The court issued a formal warning to the plaintiff, emphasizing his obligations under Federal Rule of Civil Procedure 11 to verify the accuracy of all facts and legal authorities in his filings, regardless of his pro se status or the source of the research.
Quoted passages contradicting the cited case's holding are red flags — read the opinion, not just the pincite.
Record details
What the record establishes about AI use
The court noted the plaintiff's misquotes may have been generated by AI.
Order denying plaintiff's motions for sanctions and striking plaintiff's motion for default judgment.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Plaintiff attributed the sentence "A conviction is not final until the completion of the direct appeal." to People v. Swafford; the Court found the quote does not appear in the opinion and noted cited passages contradict the proposition.
- False Quotes: Case Law | Plaintiff attributed the sentence "A judgment is not final while an appeal of right remains pending." to People v. Kennedy; the Court found the quote does not appear in the opinion.
- Fabricated: Case Law | Plaintiff cited "People v. Smith, 489 Mich. 292, 311 (2011)" for the proposition "A conviction pending on direct appeal is not a final adjudication." The Court was unable to locate the cited case and treated the citation as fabricated.
- Fabricated: Case Law | Plaintiff cited "Savin v. City of Cleveland, 2022 WL 3715087 (6th Cir. 2022)"; the Court found the Westlaw citation pointed to an unrelated brief and could not locate a case by that name, indicating a likely mis-citation or fabrication.
Questions this record answers
- What happened in Patrick C. Shaltry, I v. Brent Benzing, et al.?
- The court issued a formal warning to the pro se plaintiff regarding the inclusion of fabricated citations and false quotations in his filings. The court explicitly cautioned that further misrepresentations of fact or law would result in a recommendation for sanctions under Federal Rule of Civil Procedure 11.
- Why does Patrick C. Shaltry, I v. Brent Benzing, et al. matter for legal AI risk?
- Quoted passages contradicting the cited case's holding are red flags — read the opinion, not just the pincite.
- What does the public record establish about Patrick C. Shaltry, I v. Brent Benzing, et al.?
- 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 Patrick C. Shaltry, I v. Brent Benzing, et al. 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.