Warner v. Gilbarco, Inc.
E.D. Michigan · Oct 30, 2025
- Jurisdiction
- federal
- Court
- E.D. Michigan
- Record ID
- warner-v-gilbarco-inc-2025-10-30
- Observed outcome
- The court issued a formal warning to the plaintiff regarding the use of fabricated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in E.D. Michigan, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Employment
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- Generative AI programs
- Known monetary consequence
- Not recorded
- Procedural posture
- Discovery motion hearing and order on Plaintiff's amended motion to compel and motion for protective order.
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 errors to the use of generative AI programs.
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.