Richard A. Cole v. Midland States Bank, et al.
D. Massachusetts · Jun 1, 2026
What happened in this matter?
The court admonished a pro se plaintiff for submitting an AI-generated 'AI Overview' screenshot that contained a material misrepresentation of law regarding EFTA standing. The court ruled the AI output was incorrect and warned the plaintiff against relying on such ill-founded information in future court filings.
- Why the court cared
- The court reasoned that the plaintiff's reliance on AI output to support a legal position that contradicted the plain language of the EFTA constituted a material misrepresentation, regardless of the plaintiff's pro se status.
- Why it matters now
- This case illustrates judicial intolerance for the submission of unverified AI-generated legal research, even by pro se litigants. It highlights the court's expectation that parties must independently verify the accuracy of legal propositions before presenting them to the court.
Why this matter is tracked
In a civil action involving claims under the Electronic Funds Transfer Act (EFTA), a pro se plaintiff submitted an 'AI Overview' screenshot as legal authority to support his standing as an intended recipient of a failed transfer. The court determined that the plaintiff was not a 'consumer' under the EFTA and that the AI-generated assertion was legally incorrect. The court characterized the submission of this AI output as a material misrepresentation of the law. While the court acknowledged the plaintiff's pro se status, it formally admonished him against making such ill-founded misrepresentations in future filings. The court ultimately granted the defendants' motion to dismiss all counts of the complaint.
This case illustrates judicial intolerance for the submission of unverified AI-generated legal research, even by pro se litigants. It highlights the court's expectation that parties must independently verify the accuracy of legal propositions before presenting them to the court.
Record details
What the record establishes about AI use
The plaintiff submitted a screenshot of a Google AI Overview.
The court issued a Memorandum & Order granting the defendants' motion to dismiss the plaintiff's complaint in its entirety.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Legal Norm | Pro se plaintiff submitted an AI-generated 'AI Overview' screenshot asserting that the intended recipient of a failed electronic transfer may file a claim under the EFTA; the court found this claim incorrect and a material misrepresentation.
Questions this record answers
- What happened in Richard A. Cole v. Midland States Bank, et al.?
- The court admonished a pro se plaintiff for submitting an AI-generated 'AI Overview' screenshot that contained a material misrepresentation of law regarding EFTA standing. The court ruled the AI output was incorrect and warned the plaintiff against relying on such ill-founded information in future court filings.
- Why does Richard A. Cole v. Midland States Bank, et al. matter for legal AI risk?
- This case illustrates judicial intolerance for the submission of unverified AI-generated legal research, even by pro se litigants. It highlights the court's expectation that parties must independently verify the accuracy of legal propositions before presenting them to the court.
- What does the public record establish about Richard A. Cole v. Midland States Bank, 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 Richard A. Cole v. Midland States Bank, 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.