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AI in Court

I've Seen Fake Cites on Both Sides Now (II)

Eugene Volokh | 7.21.2026 4:13 PM

From Evans v. Robertson, decided today by Judge Judith Levy (E.D. Mich.) (for the original on the Magistrate Judge's September 2025 post decision in this case, see here):

Plaintiff and Defendant's objections will be stricken because they contain factitious citations.

The litigants in this case have been repeatedly warned that factitious citations will not be tolerated by the Court. Magistrate Judge Elizabeth A. Stafford ordered Plaintiff and Defendant to "include a written representation that [they have] personally checked each legal citation and each citation is accurate and stands for its asserted proposition" and warned that a failure to do so may result in sanctions. Despite Judge Stafford's order and this Court's repeated warnings, both Plaintiff and Defendant have violated the Court's express requirements numerous times.

On November 20, 2025, the Court imposed sanctions on both Plaintiff and Defendant for their repeated use of factitious citations and have stricken the parties' filings when they contain factitious citations. The parties have been warned that additional sanctions may be imposed if future filings contain factitious citations….

Plaintiff's objections contain factitious citations. Plaintiff declares in her objection that she "reviewed the citations and........

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