Ali v. IT People Corporation, Inc.
U.S. District Court, Eastern District of Michigan · E.D. Mich. · Michigan bar guidance
Conduct
Pro se plaintiff admitted to two misrepresented quotations and one phantom citation (Mich. Admin. Code R 408.8004 does not exist).
Consequence
Inherent-authority sanction of $200 per admitted misrepresentation, $600 total, payable to defense counsel in two $300 installments.
Lesson
Patti's Ali order is the foundational $200-per-citation framework cited across the E.D. Mich. AI-sanctions docket through 2026.
Verified May 7, 2026
- Citation
- Ali v. IT People Corp., Inc., No. 2:25-cv-10815, 2025 WL 2682622 (E.D. Mich. Sept. 19, 2025) (Patti, M.J.)
- Decided
- September 19, 2025
Summary
Pro se plaintiff Khalid Ali, in briefing on a defendant's motion for sanctions and on his own motion for leave to file a second amended complaint, included misrepresented quotations from real cases and a citation to a Michigan Administrative Code regulation that did not exist. Plaintiff admitted to two misrepresentations and one phantom citation: misrepresenting Union Planters v. L&J Dev. Co., 115 F.3d 378 (6th Cir. 1997), as holding that Rule 11 sanctions are reserved for exceptional circumstances; misstating the deadline under Michigan's Bullard-Plawecki Employee Right to Know Act; and citing Michigan Admin. Code R 408.8004, a regulatory code that does not exist.
- AI tool:
- Generative AI (specific tool not identified on the record; Plaintiff admitted excessive reliance on AI-generated documents)
- Sanction amount:
- $600
What sanction did the court impose?
Magistrate Judge Anthony P. Patti, exercising the court's inherent authority, sanctioned Plaintiff $200 per admitted misrepresentation for a total of $600, payable to Defendant's counsel in two $300 installments. The first installment was due October 20, 2025; the second was held in abeyance pending good-faith compliance with the rules. The court issued a limited stay of proceedings until the first installment was paid. Defendant's separate motions for sanctions under Rule 11 and Rule 26(g)(3) were denied, with sanctions imposed instead under inherent authority.
Why does Ali v. IT People Corporation, Inc. matter for law firms using AI?
Ali v. IT People is the foundational E.D. Michigan AI sanctions order from Magistrate Judge Anthony P. Patti’s bench. Patti declined to impose Rule 11 sanctions because Defendant’s Rule 11 motion did not satisfy the safe-harbor requirements, but he found that the record supported sanctions under the court’s inherent authority because Plaintiff’s misquotations of Union Planters and Bullard-Plawecki, and his citation to a non-existent Michigan administrative code section, were “either made in bad faith, tantamount to bad faith, or in the best possible light, wantonly.” The $200-per-misrepresentation amount has since become the standard reference point in Patti’s chambers, cited in subsequent orders in Smart v. The Professional Group (2025-11-05), Warner v. Gilbarco (2025-10-30), Jones v. Experian (2025-12-30), and the Behm sanction in Jarrus v. Governor of Michigan (2025-12-02) where the court adopted Patti’s $200 figure, scaled to $300 to account for Plaintiff’s admitted ChatGPT subscription expenditures.
For E.D. Mich. practitioners, Ali signals that the inherent-authority pathway around Rule 11’s safe harbor is live: a magistrate judge can impose monetary sanctions without the 21-day safe-harbor period if the misconduct is “tantamount to bad faith.” The defense costs were paid directly to opposing counsel rather than into court, with Patti reasoning that the party “most directly injured by the offending conduct” should be the recipient. Firms with pro se adversaries in Patti’s chambers should expect the Ali framework to surface in any reply brief that flags suspect citations.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- When citing a state administrative code, verify the rule number against the official Michigan Administrative Rules database before filing.
- Treat AI-generated quotations of real cases as the highest-risk failure mode: real case names suppress scrutiny that fabricated names would draw.
- Brief any pro se client or self-represented adversary on the Ali $200/citation framework before responsive briefing in E.D. Mich.