Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided July 9, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · CA Michigan, USA · 2026-07-09

Michigan MM, Inc. v. Alea Properties

What happened

In CA Michigan, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

False Quotes (Case Law)

A quoted phrase was attributed to Travis v Preston though the opinion does not contain the language; the phrase actually appears in an inspection report and municipal code.
Misrepresented (Case Law)

Penner v Seaway Hosp was cited for waiver though that decision does not address waiver and its parallel citation was misstated.
Misrepresented (Case Law)

Shunk v State was cited for duty-to-mitigate authority but the case addresses governmental immunity, not mitigation of damages.
Misrepresented (Case Law)

Miller v Chapman Contracting was cited for the standard of review though the decision does not address that standard; citation withdrawn and replaced with other authorities.
Misrepresented (Legal Norm)

A statement of MCR 2.201(B) was presented in wording derived from FRCP 17(a)(3) that Michigan's rule does not contain; the rule was misstated.
Misrepresented (Case Law)

Beecher v Morse was cited with an incorrect parallel citation; the parallel cite was corrected.
Misrepresented (Case Law)

Omnicom of Mich v Giannetti Inv Co was cited for a particular formulation about materiality of breach that the opinion does not state verbatim; citation conformed to accurately reflect the case's treatment.
Misrepresented (Legal Norm)

A rule citation for word-count obligations misstated the subrule number and was corrected (MCR 7.212(B)(2) corrected to MCR 7.212(B)(1)).
Misrepresented (Case Law)

Michaels v Amway Corp was cited as quoting Walker & Co v Harrison; appellants corrected that Michaels relies on different authorities and adjusted the citation chain.
False Quotes (Legal Norm)

A quotation of MCR 2.202(B) omitted words without indicating omissions; the rule text omission was corrected in the filing.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Both parties filed notices of errata

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: Damien Charlotin's public AI Hallucination Cases Database (CC0).