Smart v. The Professional Group
U.S. District Court, Eastern District of Michigan · E.D. Mich. · Michigan bar guidance
Conduct
Pro se Plaintiff filed twelve procedurally defective motions and two notices the court flagged as resembling AI-generated templates.
Consequence
Twelve motions denied, two notices stricken, formal warning under Rule 11 with reference to Ali v. IT People.
Lesson
Patti now flags template-like ADA notices as a possible AI-generation marker, even before identifying specific phantom citations.
Verified May 7, 2026
- Citation
- Smart v. Pro. Grp., No. 4:25-cv-11833, 2025 WL 3091139 (E.D. Mich. Nov. 5, 2025) (Patti, M.J.)
- Decided
- November 5, 2025
Summary
Pro se Plaintiff Hapree Smart filed twelve motions and two notices in October 2025 that Magistrate Judge Anthony P. Patti found procedurally defective. The court flagged that the ADA notice filed by Plaintiff "looks strikingly familiar to ones seen in other recent cases," which the court treated as a marker of possible AI-generated boilerplate. Patti issued an omnibus order memorializing an October 23 minute entry, striking Plaintiff's notices (ECF Nos. 24 and 31), denying twelve motions filed between October 28 and 31, and including a formal warning regarding generative AI use.
- AI tool:
- Generative AI (specific tool not identified; use inferred from filing patterns matching prior AI-generated ADA notices observed in other cases)
What sanction did the court impose?
Twelve motions denied; two notices stricken; Plaintiff warned about potential AI-generated phantom citations under Fed. R. Civ. P. 11. The court directed parties to the Ali v. IT People framework as the governing standard for AI-related sanctions in E.D. Michigan. No monetary sanction imposed in this order.
Why does Smart v. The Professional Group matter for law firms using AI?
Smart v. The Professional Group documents an emerging pattern in Patti’s chambers: the court is now flagging procedurally defective filings that “look strikingly familiar” across multiple pro se cases as a possible marker of generative AI use, even without identifying a specific phantom citation. Patti’s reasoning is that AI-generated form filings tend to recur because the underlying tool produces similar output across users querying similar fact patterns. This is a softer trigger than the explicit “I used ChatGPT” admission that drove Ali, but it produces the same procedural outcome: a formal warning and a directive to read the Ali $200-per-citation framework.
For E.D. Mich. litigants, the practical implication is that the warning threshold has lowered. Counsel encountering a pro se filing with template-like statutory recitations or boilerplate ADA-notice language now has a basis to flag the filing for Patti’s chambers and request that any subsequent AI-generated phantom be sanctioned under the Ali framework. The Smart warning was cited by Magistrate Judge Stafford in her January 2026 Hardy v. Whitaker report and recommendation, where she relied on Smart’s discussion of AI-generated phantom cases as part of the rationale for a vexatious-litigant injunction.
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.
- Boilerplate ADA notices, demand letters, or form-style filings recurring across pro se cases are an emerging trigger for Rule 11 scrutiny in Patti's chambers.
- An adversary's use of repetitive template language with statutory citations should prompt a verification pass against the underlying authority.
- The Smart warning is now cited in subsequent E.D. Mich. orders (Hardy v. Whitaker, Jan 2026) as part of the cumulative AI-misuse record in the district.