Zlatkin v. Gladwin County, et al.
E.D. Michigan · Feb 20, 2026
What happened in this matter?
The court issued a formal warning to the pro se plaintiff regarding the inclusion of fabricated case law in her filings. The judge explicitly admonished the plaintiff that any further citation to nonexistent authority or assertion of arguments lacking support in law or fact will result in the imposition of sanctions.
- Why the court cared
- Fabricated: Case Law | Plaintiff cited 'Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022)'; the Court determined no such decision exists and noted a different similarly titled decision does not support plaintiff's recusal argument. || Fabricated: Case Law | Plaintiff cited 'ABC Corp. v. XYZ Inc., 123 F.3d 456 (6th Cir. 2019)'; the Court found that citation to be nonexistent and not a valid binding authority.
- 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 civil rights action, the District Court for the Eastern District of Michigan overruled the plaintiffs' objections to a Magistrate Judge's Report and Recommendation. During the briefing, the pro se plaintiff Peggy Zlatkin cited two nonexistent legal authorities: 'Wells v. UPS Airlines' and 'ABC Corp. v. XYZ Inc.' The Court identified these citations as fabricated, noting that the purported 'Wells' case did not exist in the cited reporter and that the 'ABC Corp.' citation was also nonexistent. The Court adopted the Magistrate Judge's recommendation to deny the plaintiff's motion for summary judgment and motion for disqualification. The Court issued a formal admonishment to the plaintiff, warning that future citations to nonexistent authority or unsupported legal arguments will result in sanctions.
This record documents a Pro Se Litigant filing issue in E.D. Michigan, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court record does not name a tool, but the nature of the errors implies AI usage.
Opinion and Order adopting a Magistrate Judge's Report and Recommendation, overruling objections, and denying various motions including summary judgment and disqualification.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited 'Wells v. UPS Airlines, -- F. Supp. 3d --, 2022 WL 1234567 (W.D. Ky. Mar. 30, 2022)'; the Court determined no such decision exists and noted a different similarly titled decision does not support plaintiff's recusal argument.
- Fabricated: Case Law | Plaintiff cited 'ABC Corp. v. XYZ Inc., 123 F.3d 456 (6th Cir. 2019)'; the Court found that citation to be nonexistent and not a valid binding authority.
Questions this record answers
- What happened in Zlatkin v. Gladwin County, et al.?
- The court issued a formal warning to the pro se plaintiff regarding the inclusion of fabricated case law in her filings. The judge explicitly admonished the plaintiff that any further citation to nonexistent authority or assertion of arguments lacking support in law or fact will result in the imposition of sanctions.
- Why does Zlatkin v. Gladwin County, et al. 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 Zlatkin v. Gladwin County, et al.?
- 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 Zlatkin v. Gladwin County, et al. 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.