Key Takeaways
- The Michigan Court of Appeals imposed financial sanctions on attorney Ronnie Cromer Jr. for repeatedly citing AI‑generated, non‑existent case law in a medical‑malpractice appeal.
- Cromer blamed his errors on an “over‑reliance on artificial intelligence research tools,” but the court found he also used AI to draft a correction that still contained faulty citations.
- The three‑judge panel emphasized that AI does not relieve attorneys of their professional duty to verify authority, stating that “the use of such technology does not alter an attorney’s professional obligation.”
- Sanctions are to be paid personally by Cromer, and the case has been remanded to Oakland County Circuit Court to determine damages, including reasonable attorney fees, incurred by the defendants.
- The opinion was forwarded to the Michigan Attorney Grievance Commission for possible investigation, highlighting growing concerns about AI‑induced inaccuracies in legal practice and other fields.
Court sanctions attorney for AI‑generated fictitious citations
On June 17, 2026, the Michigan Court of Appeals released a published opinion ordering financial sanctions against Ronnie Cromer Jr., a Southfield attorney, after he repeatedly cited cases that either did not exist or misstated the law in an appeal he filed. The court’s nine‑page decision, authored by Judge Matthew Ackerman on behalf of a three‑judge panel, focuses heavily on Cromer’s conduct rather than the merits of the underlying medical‑malpractice suit, which the panel ultimately ruled in favor of the doctor and hospital. The opinion notes that Cromer “blamed artificial intelligence when called out on the fake precedents he cited and filed a correction,” but the panel found that his reliance on AI persisted even after being alerted to the problem.
Repeated reliance on AI without verification
According to the opinion, Cromer filed a series of motions in 2024 and 2025 that contained fabricated legal authorities. The panel wrote that Cromer demonstrated “repeated reliance on artificial intelligence without meaningful verification, despite having been alerted more than once that his filings contained fabricated authority.” In his initial filings, Cromer cited cases that were wholly invented or misrepresented existing rulings to support his arguments. When opposing counsel and the court pointed out the inaccuracies, Cromer submitted a “Notice of Correction” in which he accepted “full responsibility” for the false citations and attributed the mistake to “an over‑reliance on artificial intelligence research tools.”
AI used to draft the correction, perpetuating errors
The court’s scrutiny did not end with the original filings. At oral argument, Cromer acknowledged that he had again turned to AI to prepare the Notice of Correction. The panel recorded this admission, quoting the court: “At oral argument, counsel acknowledged he used artificial intelligence to prepare the Notice of Correction.” Despite substituting some real cases for the fabricated ones, the authorities Cromer cited in the correction still failed to support the legal propositions he advanced. The opinion states that “the valid authorities he cited still did not support the legal propositions for which Cromer offered them.” This continued misuse prompted the panel to view Cromer’s conduct as a pattern rather than an isolated slip‑up.
Judicial reasoning: AI does not replace professional duty
Judge Ackerman’s opinion makes a clear statement about the limits of technology in legal practice. He wrote, “Artificial intelligence may be a useful tool for legal research and drafting, but the use of such technology does not alter an attorney’s professional obligation.” The panel stressed that lawyers remain responsible for verifying the accuracy of any authority they rely on, regardless of whether the source is a traditional library, an online database, or an AI‑generated summary. By failing to verify the AI‑produced citations, Cromer violated his duty of competence and candor toward the tribunal, the opposing party, and the court itself.
Sanctions, remand, and referral to grievance commission
Because Cromer’s actions caused unnecessary work for the defendants’ attorneys and forced the court to “expend judicial resources disentangling plaintiff’s arguments from authorities that either did not exist or did not say what counsel represented them to say,” the panel ordered him to pay financial sanctions personally. The case was sent back to the Oakland County Circuit Court to determine the exact amount of damages, including reasonable attorney fees, that the defendants incurred as a result of what the panel termed a “vexatious appeal.” Additionally, the clerk of the court was instructed to forward the opinion to the Michigan Attorney Grievance Commission “for possible investigation,” signaling that Cromer’s conduct may trigger disciplinary proceedings beyond the financial penalties imposed by the appellate court.
Broader implications for AI in law and beyond
The Cromer case joins a growing list of incidents where AI‑generated content has introduced factual errors into professional work, ranging from academic essays to political speeches. Legal commentators warn that as AI tools become more sophisticated and accessible, the temptation to rely on them for quick research may increase, but the fundamental ethical obligations of lawyers—competence, diligence, and candor—remain unchanged. The Michigan Court of Appeals’ emphatic reminder that “the use of such technology does not alter an attorney’s professional obligation” serves as a cautionary note for the profession: technology can aid, but it cannot replace the lawyer’s responsibility to verify, contextualize, and affirm the authority upon which legal arguments rest. As courts, bar associations, and regulators grapple with the rise of AI, decisions like this one may shape future guidelines on permissible AI use, required verification steps, and the consequences of failing to uphold the standards of the legal profession.
https://www.freep.com/story/news/courts/2026/06/20/financial-sanctions-attorney-ronnie-cromer-artificial-intelligence-motions/90610320007/