Jones v. Experian Information Solutions, Inc. (E.D. Mich.)
U.S. District Court, Eastern District of Michigan · E.D. Mich. · Michigan bar guidance
Conduct
Pro se Plaintiff's arbitration-stay opposition characterized a Sixth Circuit case in a way the court found inconsistent with its holding.
Consequence
Motion to stay discovery granted; warning issued to Plaintiff regarding generative AI use under the Ali framework.
Lesson
Patti treats single case misrepresentations as AI-warning triggers, citing Charlotin's 490-filing catalog via Detroit Legal News.
Verified May 7, 2026
- Citation
- Jones v. Experian Info. Sols., Inc., No. 2:25-cv-10114 (E.D. Mich. Dec. 30, 2025) (Patti, M.J.)
- Decided
- December 30, 2025
Summary
Pro se Plaintiff Rachel Jones filed an opposition to Defendant's motion to stay discovery pending arbitration that included a characterization of a Sixth Circuit case the court found suspect. Magistrate Judge Anthony P. Patti, ruling on Defendant's motion to stay, granted the stay and added a footnote expressing "concern about the possibility that she was led astray by generative artificial intelligence." The court warned both parties that AI chatbots are designed to mimic patterns of words probabilistically and that even good-faith reliance on AI output without verification may warrant Rule 11 sanctions.
- AI tool:
- Generative AI (specific tool not identified on the record; court inferred AI use from misuse of a Sixth Circuit case in arbitration briefing)
What sanction did the court impose?
Defendant's motion to stay discovery pending arbitration granted. Plaintiff warned regarding generative AI use; court cited the Detroit Legal News reporting on Damien Charlotin's catalog of at least 490 court filings between May and October 2025 containing AI hallucinations. The court directed parties to the Ali v. IT People $200-per-citation framework. No monetary sanction imposed.
Why does Jones v. Experian Information Solutions, Inc. (E.D. Mich.) matter for law firms using AI?
Jones v. Experian shows Patti applying the Ali framework reactively: when reviewing Plaintiff’s opposition to a motion to stay, the court spotted a single mischaracterization of a Sixth Circuit case and treated it as enough to warrant a footnote-level AI warning, with the full doctrinal apparatus (Seither & Cherry, Ali, Sanders v. United States) cited as supporting authority. The order is procedurally narrow, granting a discovery stay pending an arbitration determination, but the AI warning is the substantive payload.
The Jones order includes a public-reporting citation worth noting. Patti cites “Mistake-Filled Legal Briefs Show the Limits of Relying on AI Tools at Work,” The Detroit Legal News (Oct. 31, 2025) at 18, summarizing French data scientist Damien Charlotin’s catalog of “at least 490 court filings” between May and October 2025 that contained AI hallucinations. This is the first E.D. Mich. order to cite the Charlotin catalog by name through a Detroit Legal News news item, signaling that the court is treating the catalog as part of the public record on the scope of the problem. Firms briefing AI-related issues in E.D. Mich. can cite the same Charlotin source as authority for district-wide trend data.
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.
- FCRA-class plaintiffs' attorneys handling pro se referrals should screen for AI-generated case characterizations before filing in E.D. Mich.
- Patti's 2025-12-30 footnote cites public reporting on the Charlotin catalog by name; firms can reference this catalog in their own briefing as evidence of district-wide AI misuse trends.
- An arbitration-stay motion is a low-stakes vehicle for a court to issue an AI warning; counsel responding to such motions should expect the warning to land in the order even if the motion outcome is favorable.