Patrick C. Shaltry v. Donna Collins, et al.
E.D. Michigan · Jun 2, 2026
- Jurisdiction
- federal
- Court
- E.D. Michigan
- Record ID
- patrick-c-shaltry-v-donna-collins-et-al-2026-06-02
- Observed outcome
- The court accepted the Magistrate Judge's report and recommendation, dismissed two defendants, and denied the plaintiff's motions for reconsideration, stay, and leave to file.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Civil Rights
- Trial
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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
The court noted the use of AI tools for unverified citations.
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.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.