Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC
U.S. District Court for the Eastern District of Michigan · E.D. Mich. · Michigan bar guidance
Verified April 24, 2026
- Citation
- Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC, No. 23-11310 (consolidated with No. 23-11342) (E.D. Mich. July 28, 2025) (ECF No. 81)
- Decided
- July 28, 2025
Summary
Consolidated cases (Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC, No. 23-11310, and AP Electric, Inc. v. Oakland Automation, LLC, No. 23-11342). In responsive summary judgment briefings, plaintiffs' counsel submitted citations to real cases but with fabricated quotations and explanatory parentheticals that did not accurately reflect the cases' holdings (primarily on page 12 of both response briefs). Judge F. Kay Behm identified the pattern as consistent with AI-generated content and issued a show cause order under Fed. R. Civ. P. 11(b)(2) and (c).
- AI tool:
- Generative AI / large-language model (unspecified; counsel acknowledged using 'artificial intelligence' to supplement research)
- Sanction amount:
- $1,485.00
What sanction did the court impose?
Judge F. Kay Behm issued a Consolidated Opinion and Order Imposing Sanctions on July 28, 2025. The court did not find bad faith (declining sanctions under inherent power) but imposed Rule 11 sanctions on an objective reasonableness standard. Plaintiffs' counsel (not the plaintiffs themselves) were ordered to pay $1,485.00 directly to defense counsel, representing defense costs incurred addressing the false citations. The court emphasized that real case names with fabricated quotations are particularly dangerous because recognizable cites may receive less scrutiny than unfamiliar ones. Judge Behm encouraged but did not require Plaintiffs' counsel to complete CLE on the use of LLMs in legal research and legal ethics.
Why does Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC matter for law firms using AI?
Seither v. Oakland Automation adds an important refinement to AI citation doctrine: judges now recognize that credible-sounding case names pose a heightened risk of deception because they suppress scrutiny. For E.D. Michigan practitioners, the case establishes that Rule 11 applies regardless of good faith, and that demonstrable reliance on AI without verification triggers sanctions despite the attorney’s subjective belief in the citations’ accuracy.
Sources
Primary sources
Further reading
- Specific names of sanctioned plaintiffs' counsel not identified by name in the order text (the order refers to 'Plaintiffs' counsel' collectively without naming individual attorneys).