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Courts on AI / Fabricated or misquoted citations

Seifert v. Nationstar Mortgage LLC, et al.

United States District Court for the District of Idaho · Federal district courts · ID · · No. 4:25-cv-00645-DCN · memorandum opinion

District of Idaho on 2026-02-12 in Seifert v. Nationstar Mortgage LLC, et al. found the self-represented party's response cited McGinnis v. GMAC Mortgage for propositions the court found fabricated or hallucinated. The court granted the dismissal motions and judicial-notice request, dismissed the complaint without prejudice, and allowed an amended complaint.

Disposition
The court dismissed the complaint without prejudice and required any amended complaint to verify that all legal citations are accurate and exist.
Recorded conduct
Seifert’s complaint cited McGinnis v. GMAC Mortgage Corp., 2013 WL 1282124 (D. Colo.), but that Westlaw citation pointed to an appellate brief from Washington. — outcome: warning; actor: litigant in person
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

standing as government actors in their efforts.” Deville v. Specialized Loan Servicing, LLC, 2020 WL 13267725, at *5 (C.D. Cal. Sept. 9, 2020). Finally, the problems are not just substantive. Seifert’s Complaint appears to contain fabricated or hallucinated case citations. For example, Seifert cites “McGinnis v. GMAC Mortg. Corp., 2013 WL 1282124 (D. Colo.).” Dkt. 1-2, at 6. However, 2013 WL 1282124 is not a case called McGinnis v. GMAC Mortgage Corp., nor is it from the District of MEMORANDUM DECISION AND ORDER - 7 Case 4:25-cv-00645-DCN Document 15 Filed 02/12/26 Page 8 of 10

Authorities cited in the passage: McGinnis v. GMAC Mortg. Corp., 2013 WL 1282124 (D. Colo.) · McGinnis v. GMAC Mortg. Corp., 2013 WL 1282124 · Deville v. Specialized Loan Servicing · WL 1282124 is not a case called McGinnis v. GMAC Mortgage Corp

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