LANSING — The Michigan Court of Appeals has ordered financial sanctions against an attorney and referred him to the Attorney Grievance Commission for using artificial intelligence to cite non-existent cases in an appeal he filed.
The attorney, who is not named in the June 17 published opinion but who court records identify as Ronnie Cromer Jr. of Southfield, blamed artificial intelligence when called out on the fake precedents he cited and filed a correction, according to the opinion. But the court found that Cromer also used artificial intelligence to write the correction he filed, resulting in further erroneous citations.
It’s the latest example of how widespread use of artificial intelligence software is resulting in authenticity and accuracy failings in areas ranging from academic essays to political speeches to the law.
“Artificial intelligence may be a useful tool for legal research and drafting, but the use of such technology does not alter an attorney’s professional obligation,” Court of Appeals Judge Matthew Ackerman wrote on behalf of a three-judge panel.
The panel’s ruling related to Cromer’s handling of a medical malpractice suit. The panel ruled in favor of the doctor and hospital that Cromer’s client was suing, but focused much of the nine-page opinion on Cromer’s conduct.
Cromer did not immediately respond to telephone and email messages June 18.
The court cited Cromer’s “repeated reliance on artificial intelligence without meaningful verification, despite having been alerted more than once that his filings contained fabricated authority.”
In ordering financial sanctions to be paid personally by Cromer, the panel said his actions resulted in extra work for the defendants’ attorneys and required the court “to expend judicial resources disentangling plaintiff’s arguments from authorities that either did not exist or did not say what counsel represented them to say.”
The panel sent the case back to the Oakland County Circuit Court to determine the amount of damages, including reasonable attorney fees, that defendants incurred “as a result of this vexatious appeal.”
The panel also asked the clerk of the court to forward its opinion to the Michigan Attorney Grievance Commission “for possible investigation.”
In a series of motions filed in 2024 and 2025, Cromer repeatedly cited cases that either did not exist or did not say what he claimed they said, the panel said in its opinion.
He later filed a “Notice of Correction” in which he accepted “full responsibility” for the false citations and blamed “an over-reliance on artificial intelligence research tools,” according to the opinion. But in the correction, where Cromer substituted valid legal authorities for fabricated ones, the valid authorities he cited still did not support the legal propositions for which Cromer offered them, the opinion said.
“At oral argument, counsel acknowledged he used artificial intelligence to prepare the Notice of Correction,” the court wrote.
Contact Paul Egan: 517-372-8660 or pegan@freepress.com.
This article originally appeared on Detroit Free Press: Attorney who used AI to cite fake cases sanctioned by Michigan court
Reporting by Paul Egan, Detroit Free Press / Detroit Free Press
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By Paul Egan, Detroit Free Press | USA TODAY Network
