Relying too Hard on AI Costs Injured Worker Credibility with Federal Court

The Trained A-Eye

An injured worker thought he was citing solid case law in support of his claims against his employer and its insurer, but AI led him astray -- and drew the court's ire. Simply Research subscribers have access to the full text of the decision.

Case

Muhammad v. GAP Inc., No. 2:24-cv-3676 (S.D. Ohio 07/03/25)

A worker for the Gap alleged that he incurred a shoulder injury on the job. In response to that claim, the Gap requested an independent medical examination of the worker, and during the exam, the worker objected to requests to move his arm, shoulder, and back due to pain.

The worker in federal court brought claims of discrimination and wrongful denial of disability benefits against the Gap and its insurer.

The Gap moved to dismiss.

Rule of Law

To survive a motion to dismiss, a complaint must present sufficient facts to state a claim to relief that is plausible on its face. A claim is plausible when the plaintiff pleads factual content that allows the court to draw a reasonable inference hat the defendant is liable for the misconduct alleged.

What the Court Said

In ruling in the Gap's favor, the court took issue with the worker's claims -- "conclusory allegations [that] don't provide the court with any facts" -- as well as the alleged caselaw he cited.

"It appears [the worker] has taken to putting false information before the court," the court wrote. "In at least two of his recent filings, he seems to cite to non-existent cases and/or purports to reference quotes that the court cannot find in the cases he cites as including them."

Specifically, the court noted the following deficiencies in the authority the worker was citing:

+ "In his Supplemental Evidentiaty [sic] Submission in Support of the Plaintiff's Third Amended Cpmplaint [sic] (Doc. 111), [the worker] purports to include quotes from six cases, (id. at #1612). So far as the Court can tell, none of the cases he cites in fact contain the language he quotes."

+ "In [the worker's] Motion for Recusal (Doc. 96), he asserts that the Court relied on McDonald's Corp. v. Franklin County, 2021 WL 1570922 (S.D. Ohio Apr. 21, 2021), to justify 'gagging' him. (Doc. 96, #1237-38). To start, the case the Court actually cited was In re McDonald, 489 U.S. 180, 184 (1989). But more to the point, the case he substituted does not appear to exist, or at least the Court cannot find it."

+ "In that same motion, [the worker] claims to include a quote from Obama for America v. Husted, 697 F.3d 423, 436 (6th Cir. 2012). (Doc. 96, #1226). While the case admittedly supports the purported quote substantively, so far as the Court can tell, the 'quoted' material is not in the case."

+ "[The worker] also cites Friendship Materials, Inc. v. Michigan Brick, Inc., 679 F.2d 100, 105 (6th Cir. 1982), for the proposition that he need not prove harm that is 'uncompensable by money,' a phrase he quotes, in cases involving civil rights violations. (Doc. 96, #1227). But the 'uncompensable by money' language appears nowhere in the cited case, and the case does not involve or discuss an alleged civil rights violation, but rather involves an alleged Sherman Act violation. Friendship Materials, 679 F.2d at 101-02."

+ "[The worker] further provides a purported quote from Humphrey v. U.S. Attorney General's Office, 279 F. App'x 328, 331 (6th Cir. 2008), which does not appear in that case. (Doc. 96, #1232)."

+ "Finally, and perhaps most troubling of all, [the worker] cites two cases in that motion as "controlling authority": Scott v. City of Columbus Legal Department, No. 2:21-cv-5543, 2022 WL 2828015 (S.D. Ohio July 20, 2022), and Humphrey v. U.S. Attorney General's Office, No. 2:15-cv-746, 2016 WL 740653 (S.D. Ohio Feb. 25, 2016). (Doc. 96, #1237). Neither exists."

How did all this happen?

"The court ... suspects that these inaccuracies may be the result of [the worker's] use of generative artificial intelligence (AI) technology," the court wrote. "Generative AI, at least in its current iterations, will sometimes simply 'make stuff up' or 'hallucinat[e]' quotations and/or case law."

Stepping away from the worker's specific case, the court cautioned against uncritical use of AI in workers' compensation claims.

"Litigants who simply file the material that AI tools generate, without carefully reviewing it first for accuracy, have the potential to swamp courts with what appear at first glance to be legal arguments built on law and precedent, but which are in fact nothing of the sort," the court wrote. "And not only are these problems in their own right, but ... defendants will be forced to spend more time and incur more costs parsing through copious baseless filings to defend an action, and ... courts will waste precious time doing the same in ruling on motions and moving matters along."

Verdict: The court granted the Gap's motion to dismiss.

Takeaway

Involving AI in court pleadings without subjecting it to human review could lead to significant legal troubles.

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