From Judge Judith Levy (E.D. Mich.) in Evans v. Robertson, the I've Seen Fake Cites on Both Sides Now case:
The litigants in this case … have been repeatedly warned that factitious citations will not be tolerated by the Court. Judge Stafford ordered Plaintiff and Defendant to "include a written representation that [they have] personally checked each legal citation and each citation is accurate and stands for its asserted proposition" and warned that a failure to do so may result in sanctions. Despite Judge Stafford's order, both Plaintiff and Defendant have violated the Court's express requirements and lied to the Court numerous times….
Defendant's objection, which was previously stricken by the Court, contained several factitious citations…. Plaintiff's objection contains at least two factitious citations…. Plaintiff references these factitious citations despite her declaration of verification, which states "I, the undersigned, verify that the legal authorities cited herein are accurately stated, relevant …, and drawn from controlling or persuasive precedent applicable to the issues presented in this case." …
Plaintiff's response to Defendant's objections also contains a factitious citation…. Plaintiff references this factitious citation despite her certification, which states "Plaintiff affirms that all legal authorities cited in this filing have been reviewed and verified for accuracy. All case citations were cross-checked using Westlaw and the University of Detroit Law Library, with the assistance of library staff, to ensure correct citation format, validity, and precedential status as of the date of filing." …
