Patrick Joseph Groulx v. CSL Limited
Michigan Court of Appeals · Mich. Ct. App. · Michigan bar guidance
Conduct
Here the appellant's brief cited two non-existent cases, according to the court's order.
Consequence
Appeal dismissed for egregious failure to follow the court rules; appellees may still move for vexatious-proceedings sanctions.
Lesson
Here two non-existent citations cost the appellant the appeal itself, on the appellees' motion to dismiss.
Verified September 29, 2026
- Citation
- Groulx v. CSL Ltd., No. 376637, Order (Mich. Ct. App. Dec. 19, 2025) (LC No. 25-000331-CZ) (Redford, P.J., and Wallace and Trebilcock, JJ.)
- Decided
- December 19, 2025
Summary
In a one-paragraph order, a Michigan Court of Appeals panel (Presiding Judge James Robert Redford, with Judges Randy J. Wallace and Christopher M. Trebilcock) granted the appellees' motion to dismiss the appeal of Patrick Joseph Groulx from lower-court case No. 25-000331-CZ. The court dismissed the appeal "based on appellant's egregious failure to pursue the appeal in conformity with the court rules where his appellant's brief includes citation to two non-existent cases," citing MCR 1.109(E)(5)(b) and MCR 7.211(C)(2)(b). The order does not identify the two cases, does not say who prepared the brief or whether the appellant was represented, and does not mention artificial intelligence. It does not describe the dismissal as a sanction.
- AI tool:
- Unidentified (the order cites two non-existent cases but does not mention AI or name a tool)
- Sanction amount:
- Appeal dismissed (the order does not label the dismissal a sanction); appellees' sanctions request held "not properly presented," without prejudice to a separate motion within 21 days
What sanction did the court impose?
Appeal dismissed. The appellees' request for sanctions in the same motion was held "not properly presented," because MCR 7.211(C)(8) directs that a request for sanctions for vexatious proceedings be made in a motion filed within 21 days after the order disposing of the matter. This order is without prejudice to appellees filing such a motion within 21 days after the date of this order.
Why does Patrick Joseph Groulx v. CSL Limited matter for law firms using AI?
Groulx shows how briefly an appellate court can dispose of an appeal on this ground. The entire order is one paragraph. It grants the appellees’ motion “to the extent that this appeal is DISMISSED based on appellant’s egregious failure to pursue the appeal in conformity with the court rules where his appellant’s brief includes citation to two non-existent cases,” citing MCR 1.109(E)(5)(b) and MCR 7.211(C)(2)(b).
The order says nothing more about the citations. It does not name the cases, does not describe how they came to be in the brief, and does not mention artificial intelligence; the tracker’s classification of the matter as an AI case is an inference. It also declined, on procedural grounds, to rule on the appellees’ request for sanctions, pointing them to MCR 7.211(C)(8)‘s separate-motion procedure for vexatious proceedings.
Firms documenting compliance may wish to consider that here the consequence was loss of the appeal, with a separate sanctions motion still available to the other side.
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.
- Verify every cited case exists before filing an appellate brief. Here two non-existent citations supported dismissal of the whole appeal under MCR 7.211(C)(2)(b).
- Consider the follow-on exposure the order preserved: this court left appellees free to seek vexatious-proceedings sanctions by separate motion within 21 days.
Sources
Primary sources
- AI attribution is a Charlotin tracker inference: the order cites two non-existent cases but does not mention artificial intelligence or name a tool.
- The order does not say whether the appellant was represented or self-represented, so pro_se is not set.
- Whether appellees filed a vexatious-proceedings motion, and its result, is not reflected in this order.