Sanction teardown · W.D. Michigan, USA · 2025-12-01

Lothamer Tax Resolution, Inc. v. Paul Kimmel (2)

What happened

In W.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:

• False Quotes (Case Law)
  Court found the quoted language attributed to Mickey v. Zeidler Tool & Die Co. does not appear in the cited opinion.
• Fabricated (Case Law)
  Court determined Stefanski v. City of Center Line (504 Mich. 877 (2019)) does not exist at that citation and the reference appears fabricated.
• Misrepresented (Case Law)
  Kaufman & Payton citation was used to assert a specific legal proposition the Court found the case does not support.
• Misrepresented (Case Law)
  Court noted Chandler was cited for a point the opinion does not discuss; the citation was misapplied.
• Misrepresented (Case Law)
  United States v. Garber was cited as if addressing professional responsibility, but the opinion is a tax-evasion appeal and does not support the asserted proposition.
• False Quotes (Case Law)
  Court found the quoted language attributed to Shallal v. Catholic Social Services is not present in that opinion.
• Misrepresented (Case Law)
  Wurtz was cited for propositions about knowledge and causation that the Court said Wurtz does not address.
• Fabricated (Case Law)
  Pettigrew citation does not correspond to a defamation case and the named decision does not appear to exist at that citation (fabricated/interstitial miscitation).
• False Quotes (Case Law)
  Court found the quote attributed to U.S. ex rel. Marlar does not appear in that Sixth Circuit opinion.
• False Quotes (Case Law)
  Riverview was cited for a specific maxim about pleading and amendment that the Court concluded Riverview does not contain.
• Misrepresented (Case Law)
  Court found the Olitkowski and Wolverine citations do not contain the equitable-restitution language the defendant quoted or were misapplied.
• Fabricated (Case Law)
  Wirsing citation appears to be fabricated or is an interstitial miscitation; the Court found no supporting authority at the cited source.

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

Monetary Sanction

Additional detail

Show Cause Order is here.

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/1128/Lothamer_Tax_Resolution_v._Kimmel_USA_1_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).