Case D-134 · AI Sanctions Case Tracker

Jane Doe v. Lincoln Consolidated Schools

E.D. Michigan, March 23, 2026

The case

Jane Doe v. Lincoln Consolidated Schools, E.D. Michigan, No. 2:23-cv-11236, Document 69, filed March 23, 2026. Copy of primary document: `files/sources/D-134-doe-v-lincoln-consolidated-schools.pdf`. Source URL: https://www.damiencharlotin.com/documents/1828/Doe_v._Lincoln_Consolidated_Schools_USA_23_March_2026.pdf

What happened

Plaintiffs' brief included a citation to a nonexistent "Doe v. Univ. of Mich." decision. Counsel claimed it was an accidentally combined "Frankenstein" citation, but the court found that explanation unsupported by the record and concluded the citation appeared to be an unverified AI hallucination.

The rule and the sanction

The court ordered Delaporte Lynch, PLLC to reimburse the defendants for the reasonable costs and fees associated with researching and briefing the hallucinated case. This is an adverse-costs order imposed on counsel for the AI-generated citation.

How it could have been avoided

Verify that every cited case actually exists before filing. Do not offer post hoc "Frankenstein citation" explanations that the record cannot support. Check parenthetical descriptions against the actual opinions.

Sources