Reviewing Group: State Bar Ethics Committee / Senior Judicial Policy Analysts
Abstract:
This proceeding, held on January 23, 2026, in the matters of Colon Township v. Alfred E. Yoder and Joanne Yoder (Case Nos. 250040CZ and 25533C), addresses a series of post-hearing motions filed by the defendants. Judge Jeffrey Middleton examines the defendants’ objections to a proposed order from a December 3, 2025, hearing, alongside a motion for sanctions filed by the Township.
The hearing highlights significant procedural failures by the pro se defendants, who are allegedly receiving assistance from an unlicensed third party utilizing generative AI (ChatGPT). Plaintiff’s counsel, Mr. Thornton, demonstrates that the defendants’ filings contain multiple fraudulent legal citations, including non-existent case law and misattributed holdings. Consequently, the court denies the defendants’ motions to strike the previous orders, finds their objections meritless, and grants the Township’s motion for financial sanctions under MCR 1.109(E) for the filing of frivolous and non-grounded documents. The court finalizes the restitution requirements and clarifies the defendants' right to appeal to the Michigan Court of Appeals.
Procedural Review and Hearing Summary
1:16 Case Context: Judge Middleton presides over two consolidated circuit court matters regarding zoning violations. He notes the case was inherited from Judge Studsman and expresses frustration over continued litigation following previous rulings.
3:09 Defendants’ Objection: The Yoders challenge the accuracy of the proposed order from the December 3rd hearing, arguing it is "misleading" and fails to mirror the courtroom transcript verbatim.
4:02 Warning on Unlicensed Assistance: The court identifies that the defendants are being assisted by an unlicensed individual using AI-generated content. The Judge warns that these "terrible" pleadings are legally incompetent and contain non-existent authority, leading the defendants toward financial liability.
6:13 Plaintiff's Rebuttal: Attorney Thornton outlines extensive procedural violations by the defendants, including failure to serve documents, failure to schedule hearings, and failure to provide alternative proposed orders as required by court rules.
8:54 Evidence of Citation Fraud: Counsel highlights three specific fraudulent citations in the defendants' motion to strike:
Tiedman v. Tiedman: The quoted text and holding do not exist in the cited case.
Estate of Temple Marital Trust: The case is incorrectly captioned, and the quote is non-existent.
Palazolo v. Gorska: Neither the case name nor the citation (200 Mich App 271) could be found in any legal database.
10:38 Transcript vs. Order: The court clarifies that no court rule requires a written order to mirror a transcript word-for-word, dismissing the defendants' primary legal argument for striking the order.
12:27 Request for Sanctions: The Township requests $1,624.68 in attorney fees and costs incurred since December 3, 2025, citing MCR 1.109(E), which mandates that signatures certify a document is well-grounded in fact and law.
17:33 Denial of Defense Motions: The Judge confirms that the Township's proposed orders accurately reflect his oral rulings from December. He denies the Yoders' motion to strike and their motion for an order to show cause.
19:22 Pro Se Defense of Citations: Alfred Yoder insists the citations are valid, claiming a "dumb Amishman" found a case an attorney could not; however, the court notes the citations do not exist under the provided references.
21:26 Citation Verification: The Judge confirms the citation for Palazolo v. Gorska is invalid. He notes that the defense also cited MCR 2.114(E), a court rule that was repealed in 2018.
23:28 Granting of Sanctions: The court grants the Township’s motion for sanctions. The Yoders are ordered to pay $812.34 per case (totaling $1,624.68) by February 21st.
26:24 Final Order Entry: The Judge signs the final orders, denying the defense's strike motions and confirming the restitution remains due within 21 days.
29:06 Conclusion and Appellate Rights: The court advises the defendants that further frivolous pleadings will result in additional financial sanctions and indicates that jurisdiction now rests with the Court of Appeals should they choose to proceed.