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Low reported severity Involving minors Lawsuit Dismissed

Massachusetts: federal court refuses to undo a high school's penalties on a pupil found to have submitted Grammarly AI text with invented citations

In late 2023 a junior at a public high school in Hingham, Massachusetts, and a classmate submitted a script for an AP U.S. History project that, a federal court later found on a preliminary record, contained text copied from Grammarly, a publicly available AI tool, including citations to nonexistent books, with no acknowledgement of AI use. Turnitin and other AI detection tools had flagged the script, and a school official says the pupil admitted using Grammarly. In December 2023 the school treated it as cheating: the pupil failed two parts of the project, served a Saturday detention and was rejected from the National Honor Society in spring 2024, though he was later admitted. His parents sued, arguing the school had not made its AI rules clear; on 20 November 2024 the US District Court for the District of Massachusetts refused a preliminary injunction to undo the penalties, and in February 2025 the parties dismissed the case with prejudice.

AI system
Grammarly (reported)
Occurred
Dec 2023 to Mar 2024
Reported
20 November 2024
Event location
United States
What the AI did
Communicated with the person · Made a claim about the person
Reported harm
Educational Harm
Whose AI use
Their own AI use
Setting
Education · Justice
Evidence
AI involvement reported · Causal attribution supported · 2 sources
5 claims: 4 documented, 1 reported. 2 open questions
People reported harmed
1 person

AI system as recorded: Grammarly, described by the court as a publicly available AI tool, whose generated text and invented citations the pupil copied into a project script; Turnitin and two further AI detection tools flagged the script

What Happened

The project. According to the court's memorandum and order of 20 November 2024, school officials determined in December 2023 that the pupil and another student, both juniors, had cheated on an AP U.S. History project by passing off material taken from a generative AI application. The court found, on the preliminary record, that they copied and pasted text generated by Grammarly into their script, that the first and third footnotes cited books that do not exist, and that the script cited no AI tool.

Detection. The order records that Turnitin flagged parts of the script as AI-generated when it was submitted, and that the teacher then used a revision-history extension and two further AI detection tools, which also indicated AI generation; a school official's affidavit says the pupil admitted using Grammarly to generate ideas and create portions of the script.

Consequences. The pupil received failing grades on two parts of the project and was allowed to complete the final project separately; he served a Saturday detention and in spring 2024 was rejected from the National Honor Society, though he was later allowed to reapply and was admitted. His grade for the year was a C-plus.

The suit. His parents sued teachers, officials and the school committee, contending that the school had not adequately told him how its academic honesty standards applied to AI, that the finding was unfair and that the consequences were too harsh; they asked for the detention to be expunged and the grade raised to a B. The court denied a preliminary injunction, noting a dispute over whether AI guidance was available to the class but finding the school's judgments within its discretion. In February 2025 the parties filed a stipulation dismissing all claims with prejudice and waiving appeal.

Limits. The court's findings were preliminary. The pupil's own account was not read beyond the plaintiffs' positions the order records.

Reported harm

A pupil found by the court, on a preliminary record, to have submitted Grammarly-generated text with invented citations failed two project parts, served a detention and was initially refused National Honor Society membership; his family's suit to undo the penalties failed.

How Harm Occurred

According to the court's preliminary findings, text and invented citations generated by an AI writing tool were copied into a pupil's project without disclosure; AI detection tools flagged it, and the school penalised him for cheating.

Outcome

Resolved

D. Mass. No. 1:24-cv-12437: preliminary injunction denied on 20 November 2024; stipulation of dismissal with prejudice as to all claims and parties, waiving appeal, filed 6 February 2025. The pupil was later admitted to the National Honor Society.

What remains unknown

  • The pupil's own account of how he used the tool, beyond the plaintiffs' positions recorded in the order.
  • Whether the school changed its AI guidance afterwards.

What the evidence supports

AI involvement: reported. The court found, on the preliminary record, that the pupil copied text that Grammarly, an AI tool, had generated for him into his project script, including citations to books that do not exist, and the school penalised him for submitting it as his own; the invented citations were among the evidence. Turnitin and two further AI detection tools also flagged the script as AI-generated, and a school official says he admitted using Grammarly.

5 claims: 4 documented, 1 reported. What the statuses mean

Documented The court found, on the preliminary record, that the pupil and a partner copied and pasted text generated by Grammarly, a publicly available AI tool, into the script for an AP U.S. History project, including citations to nonexistent books, without acknowledging any AI use.

Causal attribution. The court's preliminary finding; the plaintiffs disputed whether the school's AI rules were clear.

  • storage.courtlistener.com(opens in new tab) supports · English
    indiscriminately copied and pasted text that had been generated by Grammarly.com ... (“Grammarly”), a publicly available AI tool, into their draft script. ... in the submission consists of a citation to a nonexistent book ... citation to Grammarly, and no acknowledgement that AI of any kind had been used.
Reported According to the order, Turnitin flagged parts of the submitted script as AI-generated, the teacher's follow-up with revision-history and two further AI detection tools indicated AI generation, and a school official's affidavit says the pupil admitted using Grammarly to generate ideas and create portions of the script.

Causal attribution. School officials' account as recorded by the court.

  • storage.courtlistener.com(opens in new tab) supports · English
    the website flagged parts of the ... submission as AI-generated. ... two additional AI detection tools, which also indicated ... admitted that he had used Grammarly to “generate ideas” and
Documented The pupil received failing grades on two parts of the project, was required to attend a Saturday detention, and in spring 2024 was rejected from the school's National Honor Society, although he was later allowed to reapply and was admitted; his year grade in the course was a C-plus.

Causal attribution. none

  • storage.courtlistener.com(opens in new tab) supports · English
    The students received failing grades on two parts of the multi-part project, but ... was required to attend a Saturday detention, and in the ... spring of 2024, he was rejected from the school’s National Honor Society, although he was ... ultimately permitted to reapply and has since been admitted. ... grade of 78.75 (equivalent to a C-plus).
Documented The parents sued teachers, school officials and the school committee, asking the court to expunge the detention and raise the grade, and contended that the school had not adequately told the pupil how its academic honesty rules applied to AI; the court denied a preliminary injunction on 20 November 2024.

Causal attribution. none

  • storage.courtlistener.com(opens in new tab) supports · English
    about its standards for academic honesty as they apply to the use of AI, that ... from a C-plus to a B. ... For the foregoing reasons, Plaintiffs’ motion for preliminary injunction is DENIED.
Documented The parties filed a stipulation of dismissal with prejudice as to all claims and all parties, waiving appeal, in February 2025.

Causal attribution. none

  • storage.courtlistener.com(opens in new tab) supports · English
    image of the filed stipulation: STIPULATION OF DISMISSAL WITH PREJUDICE ... with prejudice as to all claims and all parties, waiving the right to appeal

Sources

2 sources inspected. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in English on 2026-10-23 (CourtListener RECAP copy of ECF 30, HTTP 200, 47 pages); no translation. Memorandum and order of 20 November 2024 on the plaintiffs' motion for a preliminary injunction, based on affidavits, exhibits and hearing testimony from both sides; its findings are preliminary. Applies to s1.

Image-only scan (CourtListener RECAP copy of ECF 40, HTTP 200); the page was rendered and read visually by the research agent (an AI) on 2026-10-23 because no text layer or OCR was available; no human reviewer read it. Stipulation of dismissal filed 6 February 2025. Applies to s2.

Event countries: United States. Affected-person countries: United States. Court countries: United States.

The pupil attended Hingham High School in Massachusetts, where the project was submitted and the discipline imposed; the suit was in the District of Massachusetts.

Reviewed for publication 2026-10-23: Published as a core case (communicated_with): according to a federal court's preliminary findings, a pupil submitted text and invented citations generated for him by an AI writing tool and the school penalised him; the court refused to undo the penalties and the suit was dismissed with prejudice. The pupil is not identified.

People described

A high school junior in Hingham, Massachusetts, a minor, disciplined for AI use on a history project; not named

People reported harmed in this case

1 person

1 AI participant · 0 other people harmed

One person: the pupil whose discipline the suit concerned (ECF 30). The partner student is not counted because the order describes no suit or consequence detail for that student beyond the shared failing grades, and is not identified.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Tags

#school#ai-writing-tool#academic-integrity#discipline#lawsuit#hallucinated-citations

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). Massachusetts: federal court refuses to undo a high school's penalties on a pupil found to have submitted Grammarly AI text with invented citations. AI incidents. https://nope.net/incidents/2023-massachusetts-high-school-pupil-penalised-for-submitting-ai-text-with-invented-citations-federal-court-refuses-to-undo-penalties

BibTeX

@misc{2023_massachusetts_high_school_pupil_penalised_for_submitting_ai_text_with_invented_citations_federal_court_refuses_to_undo_penalties,
  title = {Massachusetts: federal court refuses to undo a high school's penalties on a pupil found to have submitted Grammarly AI text with invented citations},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2023-massachusetts-high-school-pupil-penalised-for-submitting-ai-text-with-invented-citations-federal-court-refuses-to-undo-penalties}
}

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