Sanction teardown · Attorney Discipline Board (Michigan), USA · 2026-07-28
Grievance Administrator v. Mandy Pecher
What happened
In Attorney Discipline Board (Michigan), USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:
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Misrepresented (Case Law)Respondent cited Weymers v. Khera as supporting the standard for motions for reconsideration; court found the cited case does not address that standard and does not support the proposition.
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Fabricated (Case Law)Multiple non-existent Michigan appellate decisions cited in an April 30, 2026 Motion for Relief from Judgment; respondent later admitted some of these do not exist in a Notice of Errata.
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Fabricated (Case Law)Multiple fabricated Michigan Court of Appeals unpublished opinions cited in May 9 and May 20 motions; court found the listed opinions do not exist and attributed their creation to ChatGPT.
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Fabricated (Case Law)Fabricated Michigan appellate opinion cited in a June 5 motion to set aside an order; court found the case does not exist.
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False Quotes (Legal Norm)Respondent quoted language attributed to MCR 2.603 that does not appear in that rule; court found the quoted text inaccurate and the rule inapplicable to the motion.
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Misrepresented (Case Law)Respondent cited Byington v. Byington for the proposition Michigan law requires equitable allocation of tax liabilities and refunds; court found the case exists but does not support that proposition.
Which AI tool
ChatGPT. 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
Circuit Court denied the challenged motions and imposed $200 per motion in sanctions (total $800) for filing motions containing fabricated or unsupported authorities and barred further filings until sanctions were paid; Grievance Administrator filed a formal disciplinary complaint. (monetary penalty: 1 .)
Additional detail
The respondent lawyer used ChatGPT to draft multiple court motions that contained numerous fabricated case citations and misattributed or unsupported quotations of law. The circuit court found many cited cases did not exist, some real authorities were cited for propositions they do not support, and at least one rule was misquoted. The court concluded the filings violated MCR 1.109(E) and sanctioned the filer $200 per offending motion (total $800), denied the motions on that basis, and the Grievance Administrator has filed a disciplinary complaint alleging violations of professional conduct rules.
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.
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Source: https://www.damiencharlotin.com/documents/2766/Formal_Complaint_-_Grievance_Administrator_v_Mandy_Pecher_Case_No._26-72-GA.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).