Was Barber v. Morawa sanctioned over AI-generated citations?

Barber v. Morawa (CA Michigan, June 17, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Sanction ordered against plaintiff's counsel personally; actual damages and reasonable attorney fees to be determined on remand.. No monetary penalty in this order.

Which AI tool was involved in Barber v. Morawa?

The order in Barber v. Morawa does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

June 17, 2026 · AI sanctions database

Barber v. Morawa

Barber v. Morawa is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: CA Michigan
Date: June 17, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Sanction ordered against plaintiff's counsel personally; actual damages and reasonable attorney fees to be determined on remand.
Penalty: No monetary penalty in this order.

Fine

What the record shows

In a published opinion, the Michigan Court of Appeals affirmed the denial of the plaintiff's motion for a new trial and separately addressed plaintiff's counsel's repeated reliance on authority the court found to be unsupported or nonexistent. The court stated that counsel cited a case that does not exist and cited real authorities for propositions they do not support, and that a later Notice of Correction, itself prepared with the assistance of artificial intelligence, attributed quotations and legal propositions to cases that did not contain them. The court held this conduct violated MCR 7.216(C)(1) and MCR 1.109(E)(5), that sanctions were mandatory under MCR 1.109(E)(6), and remanded for the trial court to determine the actual damages and expenses, including reasonable attorney fees, to be paid by plaintiff's counsel personally. The amount was left for determination on remand.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · CA Michigan

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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