Courts on AI / Fabricated or misquoted citations

In re Mahar

United States Bankruptcy Court for the Eastern District of Virginia · Federal bankruptcy courts · VA · 2026-07-31 · 2026 WL 2220314 · No. 25-72454-SCS; Adv. No. 25-07027-SCS · memorandum opinion

Fabricated or misquoted citations Competence, fees and billing

The Eastern District of Virginia bankruptcy court dismisses Alicia Mahar’s adversary complaint for lack of jurisdiction. Footnotes note that counsel cited a nonexistent In re Coastal Carolina Fruit Company decision and supplied incorrect court, Westlaw, or date information for three other mortgage cases.

Disposition: The bankruptcy court dismissed the adversary complaint without prejudice for lack of subject-matter jurisdiction.
Recorded conduct: Plaintiff’s counsel cited a nonexistent bankruptcy case and three existing-case names with incorrect court, Westlaw, or date information. — outcome: other; actor: lawyer
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.

At the March 26, 2026 hearing, the Court advised Ms. Mahar's counsel that one of the cases he cited in support of this proposition does not exist. ECF No. 61, Transcript of Mar. 26, 2026 hearing, at 9-10. Despite extensive efforts, the Court was unable to locate any case by the alleged name, and its case citation within the response returned a completely unrelated case that is criminal in nature. See ECF No. 34, at 4 (citing the non-existent case titled In re Coastal Carolina Fruit Company). ... In support of this argument, Ms. Mahar's counsel cites three cases for which the United States District Court and Westlaw case numbers, as well as the decision dates, are incorrect. See ECF No. 34, at 2 (cases of Jennings v. RoundPoint Mortgage Servicing Corporation; Mastin v. Ditech Financial, LLC; and Heflin v. PHH Mortgage Corporation). The Court advised Ms. Mahar's counsel of the discovery of the incorrect case information at the March 26, 2026 hearings. ECF No. 61, at 9-10. The Court further advised counsel of a fourth case name contained in the pleading that was nonexistent (the citation for which related to a criminal case). Id. at 10; see n.12, supra.

Authorities cited in the passage: In re Coastal Carolina Fruit Company · Jennings v. RoundPoint Mortgage Servicing Corporation · Mastin v. Ditech Financial, LLC · Heflin v. PHH Mortgage Corporation · 28 U.S.C. § 1334

Court document: damiencharlotin.com · archived copy
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Official source not obtained within allotted attempts; read the court-authored document from the Charlotin mirror and marked link-only.

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