Richard A. Cole v. Midland States Bank, et al.
D. Massachusetts · Jun 1, 2026
- Jurisdiction
- federal
- Court
- D. Massachusetts
- Record ID
- richard-a-cole-v-midland-states-bank-et-al-2026-06-01
- Observed outcome
- The court granted the defendants' motion to dismiss and issued a formal admonishment to the plaintiff regarding his use of AI-generated legal authority.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Pro Se
- Misrepresented Authority
- Contract
- Trial
- Warning
- AI attribution
- Explicitly Recorded
- Recorded tool
- Google AI Overview
- Known monetary consequence
- Not recorded
- Procedural posture
- The court issued a Memorandum & Order granting the defendants' motion to dismiss the plaintiff's complaint in its entirety.
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 plaintiff submitted a screenshot of a Google AI Overview.
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
- Implement mandatory verification protocols for all legal research derived from generative AI tools.
- Ensure that any AI-generated content is cross-referenced against primary legal authorities before inclusion in court filings.
- Establish internal review procedures to identify and correct potential misrepresentations of law in draft documents.