Courts on AI / Fabricated or misquoted citations
Darrin L. Johnson, Jr. v. Nationstar Mortgage, LLC, et al.
United States District Court for the District of Maryland · Federal district courts · MD · · No. 1:25-cv-00855-JRR · memorandum opinion
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 court ordered the self-represented party to show cause why sanctions or corrective action should not issue for the defective authorities.
- Recorded conduct
- The self-represented party filed a pleading with one fabricated case citation. — outcome: pending; 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
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