Court - Judge Name	Effective Date	Applicable To	Categories	Summary
E.D. Mich. – Judge F. Kay Behm	12/2/2025	Generative AI	Generative AI Usage	In Jarrus v. Governor of Michigan, 2025 U.S. Dist. LEXIS 234830, the pro se plaintiffs objected to the Magistrate Judge’s order for the plaintiffs to show cause for the use of GenAI in drafting their motion to amend their complaint. Judge Behm suspected that the plaintiffs again used GenAI in their objection. The court noted that the plaintiffs’ briefing appeared to be “nothing more than a copy-paste from a chatbot-style generative AI tool” with a “series of . . . false citations” of real cases with explanations that did not match the real case. Judge Behm noted that the use of GenAI for drafting without independent citation checking “unquestionably” violates Fed. R. Civ. P. 11. After the Magistrate Judge's warning (see Jarrus v. Governor of Michigan, 2025 U.S. Dist. LEXIS 221984 (E.D. Mich. Nov. 7, 2025)), the court ordered plaintiffs to show cause why they should not be sanctioned. Judge Behm highlighted that Rule 11 “imposes obligations on each and every signatory to a briefing, not just the person who was the primary drafter.” Thus, even though one of the plaintiffs did not draft the documents and only reviewed them at a “very general level” before signing, the court held her “equally responsible for the use of misrepresented or otherwise improper citations,” and warned that further misconduct could result in “a dismissal of her claims in their entirety.” Although the plaintiffs admitted to misusing GenAI (ChatGPT specifically) in their filings, the court found that sanctions were warranted. Judge Behmt adopted Magistrate Judge Patti's recommendation of $200 per GenAI citation and imposed a $600 fine ($300 per plaintiff), warning that failure to pay may result in dismissal. The court reasoned that one of the plaintiff's $20 per month spending on a ChatGPT subscription suggested an ability to pay sanctions. The court further warned that it will consider dismissal of the case if the plaintiffs file further briefings “with even a single misrepresented, misquoted, or fictitious case that is caused by the use of [GenAI].”
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Parties
E.D. Mich – Judge Anthony P. Patti	11/7/2025	Generative AI	Generative AI Usage	In Jarrus v. Governor of Michigan, 2025 U.S. Dist. LEXIS 221984 (E.D. Mich. Nov. 7, 2025), the court suspected that the pro se plaintiffs may have used GenAI in filings associated with their motion to amend their complaint. Judge Patti called such use a “bad idea” because all parties, regardless of representation status, are “held responsible for the content of their filings under Fed. R. Civ. P. 11” and that AI is not an excuse for an inaccurate submission. While the court noted that it will not directly prohibit the plaintiffs from utilizing GenAI, it “STRONGLY suggest[ed] that Plaintiffs do not attempt to utilize it and should certainly never rely on it.” Instead, the plaintiffs were cautioned of monetary sanctions imposed in other cases and directed to read Rule 11 of the Federal Rules of Civil Procedure, as they too could be sanctioned for “any misrepresentation or AI-generated ‘phantom’ citation.” The court granted plaintiffs “one final chance” at amending their complaint.
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
E.D. Mich. – Magistrate Judge Anthony P. Patti	11/5/2025	Generative AI	Generative AI Usage	In Smart v. Pro. Grp., 2025 U.S. Dist. LEXIS 218149 (E.D. Mich. Nov. 5, 2025), the court found that the pro se plaintiff had likely used AI in connection with twelve motions and two notices that she had filed. The court warned the parties that GenAI “cannot give legal advice,” and its use can lead to “misstatements of law” and citation to nonexistent cases. The court also warned the parties that sanctions have previously been imposed against attorneys and pro se litigants for GenAI misuse, and warned the parties against overreliance on GenAI tools.
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
E.D. Mich. – Magistrate Judge Anthony P. Patti	10/30/2025	Generative AI	Generative AI Usage	In Warner v. Gilbarco Inc., 2025 U.S. Dist. LEXIS 215397 (E.D. Mich. Oct. 30, 2025), the pro se plaintiff’s motion to compel discovery included one “‘phantom’ or ‘hallucinated’” citation. Although the court was not “certain[]” the fictitious citation was the product of a GenAI tool, it noted that because GenAI-hallucinated “citations are occurring in court filings with greater frequency now,” the plaintiff should read an opinion by Magistrate Judge Patti from May 2025 in which he sanctioned the plaintiff $200 for each acknowledged misrepresentation, see Ali v. IT People Corp., Inc., 2025 U.S. Dist. LEXIS 184888 (E.D. Mich. Sept. 19, 2025), and the court warned that the plaintiff could face sanctions for future filings with inaccurate citations and/or other violations of Rule 11 of the Federal Rules of Civil Procedure.
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
E.D. Mich. – Magistrate Judge Anthony P. Patti	9/19/2025	Generative AI	Generative AI Usage	In Ali v. IT People Corporation, Inc., 2025 WL 2682622 (E.D. Mich. Sept. 19, 2025), Magistrate Judge Patti issued an opinion and order addressing various motions, including the defendant’s motion for sanctions against the plaintiff. The pro se plaintiff “expressly admitted that his filings contained (at least) two misrepresentations and one ‘phantom’ or ‘hallucinated’ regulatory citation.” After reiterating that “[e]xcessive reliance on AI generated documents, without properly confirming the validity of the citations, does not excuse false statements of law,” even for pro se litigants, the court imposed sanctions of $600 on the plaintiff “to cover a portion of the attorney fees [for Defendant’s attorney] required by [plaintiff’s] misrepresentations.” The court further directed the plaintiff to familiarize himself with federal and local rules, and the court’s practice guidelines.
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Parties
E.D. Mich. – Judge F. Kay Behm	6/5/2025	Generative AI	Generative AI Usage	In the consolidated actions of Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC and AP Electric, Inc. v. Oakland Automation, LLC (No. 4:23-cv-11342-FKB-EAS), the court flagged the plaintiffs’ use of various fictitious citations in their summary judgment briefings. As a result of these “generative artificial intelligence (AI) hallucinations,” Judge Behm identified specific portions of the brief containing the suspected hallucinations and ordered the plaintiffs to either file (i) copies of the quoted cases which the court had flagged as being potential hallucinations, (ii) a short supplemental brief with “verifiable legal authority” that matches the propositions associated with the fictitious citations, or (iii) an admission that there is no existing authority to match the citations.
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Parties
E.D. Mich. Judge Shalina D. Kumar	9/11/2023	Generative AI	Generative AI Usage	In Ruggierlo, Velardo, Burke, Reizen & Fox, P.C. v. Lancaster, 2023 U.S. Dist. LEXIS 160755 (E.D. Mich., Sept. 11, 2023), the Court, in a footnote, states that the pro se defendant cites three non-existent cases in his objections. Although declining to “speculate” whether these “fabrications” were the result of “[defendant’s] imagination, a generative artificial intelligence tool’s hallucination, both, or something else entirely,” it concluded that “conduct such as citing made-up law may result in significant sanctions,” no matter the source.
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting

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