Tiffany K. v. Commissioner of Social Security
E.D. Michigan · Jan 16, 2026
What happened in this matter?
The court issued a formal warning to counsel for including a fabricated 'phantom' case citation in her brief, which the court attributed to the use of generative AI. The court admonished counsel that such conduct is not tolerated and noted that similar actions have resulted in sanctions in the past.
- Why the court cared
- Fabricated: Case Law | Counsel's brief included a non-existent case citation 'Fleck v. Comm’r of Soc. Sec.'; the Court identified it as a 'phantom' citation likely generated by AI and admonished counsel.
- Why it matters now
- Courts now name-and-shame 'phantom' citations as AI-generated — a single unverified cite is enough to trigger public admonishment.
Why this matter is tracked
In a Social Security disability appeal, the court admonished counsel for including a non-existent 'phantom' case citation, 'Fleck v. Comm’r of Soc. Sec.', in her briefing. The court identified this as a likely result of generative AI usage and warned counsel that such unconfirmed citations and AI use have previously led to sanctions in the court. While the court ultimately granted the plaintiff's motion for summary judgment and remanded the case due to errors in the ALJ's evaluation of medical listings and residual functional capacity, the court explicitly placed counsel on notice regarding the firm's briefing practices, including the use of AI and failure to comply with local rules regarding font size and issue identification.
Courts now name-and-shame 'phantom' citations as AI-generated — a single unverified cite is enough to trigger public admonishment.
Record details
What the record establishes about AI use
The court attributed the citation error to generative artificial intelligence.
The court issued an Opinion and Order granting the plaintiff's motion for summary judgment or remand and denying the defendant's motion for summary judgment, while simultaneously issuing a warning to counsel regarding briefing deficiencies.
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.
- Fabricated: Case Law | Counsel's brief included a non-existent case citation 'Fleck v. Comm’r of Soc. Sec.'; the Court identified it as a 'phantom' citation likely generated by AI and admonished counsel.
Questions this record answers
- What happened in Tiffany K. v. Commissioner of Social Security?
- The court issued a formal warning to counsel for including a fabricated 'phantom' case citation in her brief, which the court attributed to the use of generative AI. The court admonished counsel that such conduct is not tolerated and noted that similar actions have resulted in sanctions in the past.
- Why does Tiffany K. v. Commissioner of Social Security matter for legal AI risk?
- Courts now name-and-shame 'phantom' citations as AI-generated — a single unverified cite is enough to trigger public admonishment.
- What does the public record establish about Tiffany K. v. Commissioner of Social Security?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Tiffany K. v. Commissioner of Social Security 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.