Courts on AI / Fabricated or misquoted citations
Johnson v. Nationstar Mortgage LLC
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 dismisses Johnson’s mortgage-related claims and flags another hallucinated citation from the self-represented plaintiff. The court says Cooke v. Carrington Mortgage Services, as cited to the Fourth Circuit and Westlaw, does not exist, but declines further Rule 11 action because the case is dismissed.
- Disposition
- The court granted defendants' motions to dismiss and declined further action over the latest hallucinated citation.
- Recorded conduct
- Self-represented plaintiff cited nonexistent Cooke v. Carrington Mortgage Services Fourth Circuit and Westlaw authorities after a prior Rule 11 warning. — 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.
Notwithstanding the foregoing admonition, it appears Plaintiff has once again cited a “hallucinated” case derived perhaps from use of a generative artificial intelligence (“AI”) tool (e.g., ChatGPT, Gemini, etc.). Specifically, Plaintiff cites to “Cooke v. Carrington Mortg. Servs., No. 22-1425 (4th Cir. 2023),” see ECF No. 57 at p. 3. Plaintiff contends this case stands for the proposition that “servicer-imposed charges tied to improper insurance placement constitute a concrete injury.” ... Based on the court’s review, this case does not exist. The court has checked the Fourth Circuit case number—22-1425, and Westlaw citation—2023 WL 3010355—offered by Plaintiff to identify this case; neither directs the court to the referenced opinion. ... While this court has already cautioned Plaintiff that continued citation to hallucinated authorities or the like risks issuance of an order to show cause why he should not face sanctions under Rule 11, the court declines to take further action in the instant matter where Plaintiff’s case will be dismissed in full.
Authorities cited in the passage: Cooke v. Carrington Mortg. Servs., No. 22-1425 (4th Cir. 2023) · Mezu v. Mezu, 267 Md. App. 354 (2025) · Noland v. Land of the Free, L.P., 336 Cal. Rptr. 3d 897 (Cal. App. 2025) · Fed. R. Civ. P. 11
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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