Case D-62 · AI Sanctions Case Tracker

Loyer v. Wayne County Michigan

U.S. District Court for the Eastern District of Michigan, March 21, 2025

Repeat offender (verified in the record)

The case

Loyer v. Wayne County Michigan, U.S. District Court for the Eastern District of Michigan, March 21, 2025, 2025 WL 889770, Case No. 21-12589. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-62-loyer-v-wayne-county.pdf`.

What happened

In a footnote in the March 21, 2025 opinion on summary judgment, the court recorded that it had previously admonished plaintiff's counsel at a hearing for including AI-generated bogus legal citations in the response brief (ECF No. 68) and had ordered him to attend an ethics seminar. The opinion also called out brazen factual fabrications in the briefing, "perhaps also the result of counsel's inappropriate dependence on AI," and warned that further transgressions would result in disciplinary action.

The rule and the sanction

Mandatory ethics seminar order (Tier 2) imposed on plaintiff's counsel at the earlier hearing, with the March 21 opinion confirming it and adding that future transgressions would bring disciplinary action. The underlying ECF No. 68 order was not located, so this entry is grounded in the March 21 opinion; the opinion does not name counsel in its sanction discussion (footnote 2), though its "Attorneys and Law Firms" listing (p. 1) names Ronnie E. Cromer, Jr., The Cromer Law Group, PLLC, Southfield, MI, for the plaintiff, the only plaintiff's counsel listed, and the attorney admonished at the hearing. Source URL: the primary PDF (Charlotin documents archive: /documents/699/Loyer_v_Wayne_County_Michigan.pdf, https://www.damiencharlotin.com/documents/699/Loyer_v_Wayne_County_Michigan.pdf).

How it could have been avoided

Complete a verified citation check on every authority in a brief before filing. Do not file briefs containing fabricated factual or legal claims that no one has checked. Treat an admonishment for AI misuse as a mandate to change your workflow immediately.

Sources