Patrick C. Shaltry v. Donna Collins, et al.
E.D. Michigan · Jun 2, 2026
What happened in this matter?
The court identified that the pro se plaintiff submitted fabricated case law, specifically a non-existent Sixth Circuit decision, which the court attributed to the likely use of AI tools. While the court noted this pattern of false citations and misquotes, it did not impose a formal sanction, instead addressing the filings through procedural denial and judicial admonition.
- Why the court cared
- The court reasoned that the cited case 'Parris v. Pappas' does not exist and that the plaintiff's briefing contained a broader pattern of false quotations and citations, which the court characterized as unverified and likely AI-generated.
- Why it matters now
- This case illustrates judicial identification of AI-generated hallucinations in pro se filings. It highlights how courts are increasingly documenting and preserving unverified, likely AI-generated citations in the official record, even when formal sanctions are not imposed, to address systemic issues with research accuracy.
Why this matter is tracked
In a civil rights action, the court addressed a pro se plaintiff's filings, including a motion for reconsideration and a motion to stay. The court denied these motions on procedural and substantive grounds. During its review, the court identified a pattern of unreliable citations in the plaintiff's briefing. Specifically, the court highlighted that the plaintiff cited 'Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016)' to support a legal proposition, but the court determined this case does not exist. An editor's note in the opinion indicates that these unverified citations were likely generated by AI tools, though they were preserved in the record. The court cautioned the plaintiff regarding the necessity of accurate filings and adherence to procedural rules.
This case illustrates judicial identification of AI-generated hallucinations in pro se filings. It highlights how courts are increasingly documenting and preserving unverified, likely AI-generated citations in the official record, even when formal sanctions are not imposed, to address systemic issues with research accuracy.
Record details
What the record establishes about AI use
The court noted the use of AI tools for unverified citations.
Opinion and Order accepting and adopting a Magistrate Judge's Report and Recommendation, denying the plaintiff's motion for reconsideration, motion to stay, and motion for leave to file.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited a non-existent Sixth Circuit case 'Parris v. Pappas, 844 F.3d 172 (6th Cir. 2016)', which the court found does not exist and characterized as a false/fabricated citation.
- Misrepresented: Case Law | Court noted a broader pattern of misquotes, false quotations, and false citations throughout Plaintiff's briefs; an Editor's Note stated these unverified citations were likely generated by AI and preserved them in the record.
Questions this record answers
- What happened in Patrick C. Shaltry v. Donna Collins, et al.?
- The court identified that the pro se plaintiff submitted fabricated case law, specifically a non-existent Sixth Circuit decision, which the court attributed to the likely use of AI tools. While the court noted this pattern of false citations and misquotes, it did not impose a formal sanction, instead addressing the filings through procedural denial and judicial admonition.
- Why does Patrick C. Shaltry v. Donna Collins, et al. matter for legal AI risk?
- This case illustrates judicial identification of AI-generated hallucinations in pro se filings. It highlights how courts are increasingly documenting and preserving unverified, likely AI-generated citations in the official record, even when formal sanctions are not imposed, to address systemic issues with research accuracy.
- What does the public record establish about Patrick C. Shaltry v. Donna Collins, 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 v. Donna Collins, 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.