Loyer v. Wayne County, Michigan
U.S. District Court, Eastern District of Michigan, Southern Division · E.D. Mich. · Michigan bar guidance
Verified May 5, 2026
- Citation
- Loyer v. Wayne County, No. 21-12589, 2025 WL 889770 (E.D. Mich. Mar. 21, 2025)
- Decided
- March 21, 2025
Summary
Plaintiff's counsel Ronnie E. Cromer, Jr. of The Cromer Law Group, PLLC included AI-generated bogus legal citations in the response brief opposing defendants' motion for summary judgment in a Section 1983 jail-suicide case. U.S. District Judge Shalina D. Kumar admonished counsel at the March 12, 2025 hearing for the fabricated citations and separately flagged a "brazen factual fabrication" misrepresenting the decedent's medical screening record, noting the misrepresentation was "perhaps also the result of counsel's inappropriate dependence on AI."
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The court ordered plaintiff's counsel to attend an ethics seminar and warned that "further transgressions of this sort will result in disciplinary action." No monetary sanction was imposed. The court separately granted defendants' motion for summary judgment and dismissed the case with prejudice on the merits.
Why does Loyer v. Wayne County, Michigan matter for law firms using AI?
Loyer is notable for pairing AI-generated fabricated citations with a separate misrepresentation of record evidence in the same brief, which the court tied directly to “counsel’s inappropriate dependence on AI.” For managing partners, the case illustrates that AI misuse risk extends beyond invented case law to AI-generated factual summaries of the record, and that courts are willing to impose ethics-CLE sanctions for these lapses even where the underlying motion is otherwise resolved on the merits.
Sources
Primary 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.