Courts on AI / Fabricated or misquoted citations

Darrin L. Johnson, Jr. v. Nationstar Mortgage, LLC

United States District Court for the District of Maryland · Federal district courts · MD · 2026-04-30 · No. 1:25-cv-00855-JRR · memorandum opinion

Fabricated or misquoted citations

The District of Maryland on 2026-04-30 ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities in Darrin L. Johnson, Jr. v. Nationstar Mortgage, LLC, et al. The self-represented party filed a pleading with one fabricated case citation.

Disposition: The preliminary injunction was denied and Johnson was strongly cautioned that future hallucinated authority may lead to an order to show cause or sanctions.
Recorded conduct: Johnson cited nonexistent Jefferson v. U.S. Bank authority for a home-loss irreparable-injury proposition. The court described it as likely a generative-AI hallucination and strongly cautioned him. — 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.

“[I]n exercising that discretion to impose sanctions for a pleading or paper’s lack of legal support, the court must apply an objective standard, inquiring whether ‘a reasonable attorney in like circumstances could not have believed his actions to be legally justified. ’” Lokhova, 30 F. 4th at 354 (quoting Hunter v. Earthgrains Co. Bakery, 281 F. 3d 144, 153 (4th Cir. 2022)). To be sanctionable, a legal argument 3 “Fake or nonexistent legal citations typically are the result of AI ‘hallucinations. ’” Mezu v. Mezu, 267 Md. App. 354, 368 (2025), reconsideration denied (Nov. 24, 2025), cert. dismissed, 493 Md. 184 (2026) (quoting Noland v. Land of the Free, L.

Authorities cited in the passage: Hunter v. Earthgrains Co. Bakery, 281 F · Mezu v. Mezu, 267 Md · Noland v. Land of the Free

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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