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HomeCasesWarner v. Gilbarco, Inc.
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Corpus matter record

Warner v. Gilbarco, Inc.

E.D. Michigan · Oct 30, 2025

MI / federalEditorial impact: lowpro sefake citationsemploymenttrialWarning
Direct answer

What happened in this matter?

The court issued a formal warning to the pro se plaintiff after she twice submitted 'phantom' case citations in her filings. The court attributed these errors to the likely use of generative AI and cautioned that future misrepresentations or failures to comply with procedural rules would result in sanctions.

Why the court cared
Fabricated: Case Law | Plaintiff twice cited 'Smith v. Dow Chem. Co., 166 F.R.D. 1, 2 (E.D. Mich. 1996)' to argue depositions should not proceed; the court found this a 'phantom' citation and noted the actual existing opinion is Hamm v. Nasatka Barriers Inc., 166 F.R.D. 1 (D.D.C. 1996), which does not mention depositions.
Why it matters now
This record documents a Pro Se Litigant filing issue in E.D. Michigan, with the listed outcome: Warning.

Why this matter is tracked

In a discovery dispute, the court identified that the pro se plaintiff twice cited a non-existent case, 'Smith v. Dow Chem. Co., 166 F.R.D. 1, 2 (E.D. Mich. 1996),' to support her argument against proceeding with depositions. The court characterized this as a 'phantom' citation, noting the actual opinion at that citation is Hamm v. Nasatka Barriers Inc., 166 F.R.D. 1 (D.D.C. 1996), which does not address depositions. The court attributed the error to the increasing use of generative AI in legal filings. While the court declined to impose monetary sanctions at this time, it issued a formal warning that future misrepresentations or noncompliance with Rule 11 could result in sanctions.

Operational lesson

This record documents a Pro Se Litigant filing issue in E.D. Michigan, with the listed outcome: Warning.

Record details

MichiganSingle-state evidence scope
Explore MIOpen its source-linked jurisdiction page and related matters.
CourtE.D. Michigan
Jurisdictionfederal
Circuit6th Circuit
DateOct 30, 2025
GE
AI toolGenerative AI programs
Party typePro Se Litigant
OutcomeThe court issued a formal warning to the plaintiff regarding the use of fabricated citations.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

implied

The court attributed the errors to the use of generative AI programs.

Procedural posture

Discovery motion hearing and order on Plaintiff's amended motion to compel and motion for protective order.

Correction behavior

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.

  1. Fabricated: Case Law | Plaintiff twice cited 'Smith v. Dow Chem. Co., 166 F.R.D. 1, 2 (E.D. Mich. 1996)' to argue depositions should not proceed; the court found this a 'phantom' citation and noted the actual existing opinion is Hamm v. Nasatka Barriers Inc., 166 F.R.D. 1 (D.D.C. 1996), which does not mention depositions.

Questions this record answers

What happened in Warner v. Gilbarco, Inc.?
The court issued a formal warning to the pro se plaintiff after she twice submitted 'phantom' case citations in her filings. The court attributed these errors to the likely use of generative AI and cautioned that future misrepresentations or failures to comply with procedural rules would result in sanctions.
Why does Warner v. Gilbarco, Inc. matter for legal AI risk?
This record documents a Pro Se Litigant filing issue in E.D. Michigan, with the listed outcome: Warning.
What does the public record establish about Warner v. Gilbarco, Inc.?
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 Warner v. Gilbarco, Inc. 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.

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