Nai v. National Asset Mortgage, LLC
U.S. District Court, Western District of Michigan, Southern Division · W.D. Mich. · Michigan bar guidance
Verified May 5, 2026
- Citation
- Nai v. National Asset Mortgage, LLC, No. 1:24-cv-00666-JMB-SJB, ECF No. 147 (W.D. Mich. Mar. 11, 2026)
- Decided
- March 11, 2026
Summary
Counsel for defendant National Asset Mortgage, LLC (NAM), Matthew R. Reinhardt, submitted briefs that materially altered the language of 12 U.S.C. section 2614, changing the statute's accrual trigger from "the occurrence of the violation" to "the first occurrence" in both NAM's summary judgment brief and its response to plaintiff's cross-motion. Plaintiff Checks Aciek Ateny Nai flagged the misquotation in a reply brief months before the court acted, but NAM did not correct the record. Judge Jane M. Beckering issued an Order to Show Cause under Rule 11, and NAM's response admitted counsel had misrepresented the statutory text, attributing it to "inadvertent error."
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Court deemed the OSC satisfied and declined to impose Rule 11 sanctions, calling it a close question. No monetary sanction. Counsel was placed on notice that any future misrepresentation of authority will not be treated as an isolated incident.
Why does Nai v. National Asset Mortgage, LLC matter for law firms using AI?
Nai illustrates the narrower-but-still-serious cousin of the fabricated-citation cases: not invented opinions, but altered statutory text. The court declined to sanction in part because the misquotation did not infect the broader briefing and the parties spent little time on it, but Judge Beckering flagged the firm’s failure to correct the quotation after opposing counsel surfaced the error as the factor that made the call close. For managing partners, the operational lesson is that quotation-verification belongs in the same workflow as citation-verification, and that any prompt-and-paste workflow used to draft statutory analysis needs a human check against the U.S. Code before filing.
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.
- AI tool involvement is implied by the fabricated-quotation pattern; the order itself does not identify any generative AI tool by name.