Tiffany K. v. Commissioner of Social Security
E.D. Michigan · Jan 16, 2026
- Jurisdiction
- federal
- Court
- E.D. Michigan
- Record ID
- tiffany-k-v-commissioner-of-social-security-2026-01-16
- Observed outcome
- The court granted the plaintiff's motion for summary judgment and remanded the case, while issuing a formal warning to counsel regarding the use of AI and briefing errors.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Courts now name-and-shame 'phantom' citations as AI-generated — a single unverified cite is enough to trigger public admonishment.
Failure modes and consequences
- Fake Citations
- Administrative
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- Generative artificial intelligence (AI)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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 attributed the citation error to generative artificial intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Retain a matter-level record of source checks and corrections.