Patrick Joseph Groulx v. CSL Limited
Michigan Court of Appeals · Mich. Ct. App. · Michigan bar guidance
Verified May 14, 2026
- Citation
- Patrick Joseph Groulx v. CSL Limited, No. 376637 (Mich. Ct. App. Dec. 19, 2025) (LC No. 25-000331-CZ) (Redford, P.J., Wallace and Trebilcock, JJ.)
- Decided
- December 19, 2025
Summary
Appellant Patrick Joseph Groulx filed an appellant's brief that included citations to two non-existent cases. A panel of the Michigan Court of Appeals (Presiding Judge James Robert Redford, joined by Judges Randy J. Wallace and Christopher M. Trebilcock) granted appellees' motion to dismiss, finding an "egregious failure to pursue the appeal in conformity with the court rules" under MCR 1.109(E)(5)(b) and MCR 7.211(C)(2)(b). The order does not name a generative AI tool, but fabricated case citations of this kind have become the signature artifact of unverified AI-assisted brief drafting.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Appeal dismissed. Appellees' simultaneous request for sanctions was denied as procedurally improper under MCR 7.211(C)(8), but the dismissal was entered without prejudice to appellees filing a separate motion for vexatious-proceedings sanctions within 21 days of the order.
Why does Patrick Joseph Groulx v. CSL Limited matter for law firms using AI?
Groulx is a state-appellate analogue to the federal Rule 11 sanctions cases: a panel dismissed an entire appeal because the appellant’s brief cited two cases that do not exist, treating the fabrications as an “egregious failure” to follow the court rules rather than a curable defect. For a managing partner, the practical lesson is that hallucinated citations are no longer just a sanctions risk; in some courts they are now grounds for losing the appeal outright, before the merits are ever reached. The panel’s procedural note, that vexatious-proceedings sanctions must be sought in a separate, timely motion, also signals that fee-shifting exposure on the opposing side remains live.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- No CourtListener or Michigan Court of Appeals public-docket URL was located during verification; only the Charlotin-hosted S3 copy of the order was retrievable.