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Michigan · federal district court · 2026

Clark v. Social Security, Commissioner of

District Court, E.D. Michigan, 24 September 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · E.D. Mich.

  1. Court. District Court, E.D. MichiganCOURT
  2. Level. federal district courtLEVEL
  3. Date. 24 September 2026DATED
  4. Docket. No. 2:25-cv-11554DOCKET
  5. Judge. Elizabeth A. StaffordJUDGE
  6. Documents. one document, 4 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 20, 24 September 2026 · source · PDF · 7 pages

Docket text. ORDER Fining Plaintiff's Counsel for Misuse of Artificial Intelligence. Signed by Magistrate Judge Elizabeth A. Stafford. (CShr)

Modern litigation has been unended by the exploding use of generative AI. Damien Charlotin, a legal analyst, has tracked almost 1500 legal decisions about AI-generated hallucinated content in the United States.1 The hallucinated content is “typically fake citations, but also other types of AI-generated arguments.” Id.; see also Sanders v. United States, 176 Fed.

Cl. 163, 169 (2025) (“It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, 1 AI Hallucination Cases, https://www.damiencharlotin.com/hallucinations/?q=&sort_by=- date&states=USA&period_idx=0&page=2 (last visited on Sept. 23, 2026).

Case 2:25-cv-11554-EAS ECF No. 20, PageID.3762 Filed 09/24/26 Page 2 of 7 3 courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs.”). “Attorneys who rely on [AI] to supplement their research do so in light of the well-known risks inherent in using those tools.” Seither & Cherry Quad Cities, Inc. v.

9, PageID.1034. But Williams does not exist; that citation instead relates to Widi v. McNeil from the District of Maine and did not involve an application for social security.

What the text mentions

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Where this fits

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More from District Court, E.D. Michigan, from Michigan, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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