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Pizzimenti v. City of Detroit, et al.

Court
E.D. Michigan
Jurisdiction
USA
Decided
2026-03-27
AI tool
Implied
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Misrepresented: Case Law | Plaintiff cited Opulent Life Church, 697 F.3d 279 in support of fines/Eighth Amendment/retaliation arguments, but the court noted that Opulent Life Church does not involve fines nor those claims and was thus misapplied. || Fabricated: Case Law | Plaintiff cited 'Williams v. City of Cleveland, No. 1:18-CV-2911, 2019 WL 5485190 (N.D. Ohio Oct. 25, 2019),' which the court and R&R found does not exist in Westlaw or under that docket. || False Quotes: Case Law | Plaintiff quoted language attributed to Jensen v. Utah Cnty., 2025 WL 2208257 (D. Utah Aug. 4, 2025), but the quoted passage does not appear in that opinion. || Fabricated: Case Law | Complaint referenced 'Thaxton v. City of Pontiac, No. 298862, 2011 WL 522951 (Mich. Ct. App. Feb. 15, 2011),' a citation the court says does not exist. || Fabricated: Case Law | Complaint referenced 'Smith v. State, 26 N.E.3d 1167 (Ind. 2015),' which the court was unable to locate or identify as relevant.

Sanction teardown · E.D. Michigan, USA · 2026-03-27

Pizzimenti v. City of Detroit, et al.

What happened

In E.D. 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:

  • Misrepresented (Case Law)
    Plaintiff cited Opulent Life Church, 697 F.3d 279 in support of fines/Eighth Amendment/retaliation arguments, but the court noted that Opulent Life Church does not involve fines nor those claims and was thus misapplied.
  • Fabricated (Case Law)
    Plaintiff cited 'Williams v. City of Cleveland, No. 1:18-CV-2911, 2019 WL 5485190 (N.D. Ohio Oct. 25, 2019),' which the court and R&R found does not exist in Westlaw or under that docket.
  • False Quotes (Case Law)
    Plaintiff quoted language attributed to Jensen v. Utah Cnty., 2025 WL 2208257 (D. Utah Aug. 4, 2025), but the quoted passage does not appear in that opinion.
  • Fabricated (Case Law)
    Complaint referenced 'Thaxton v. City of Pontiac, No. 298862, 2011 WL 522951 (Mich. Ct. App. Feb. 15, 2011),' a citation the court says does not exist.
  • Fabricated (Case Law)
    Complaint referenced 'Smith v. State, 26 N.E.3d 1167 (Ind. 2015),' which the court was unable to locate or identify as relevant.

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

Warning

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: https://www.damiencharlotin.com/documents/1877/Pizzimenti_USA_27_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1877/Pizzimenti_USA_27_March_2026.pdf

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