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Incident Tracker / United States (federal)

Johnson v. Nationstar Mortgage LLC, No. 1:25-cv-00855-JRR (D. Md.)

·US District Court, District of Maryland·US-FEDWarning

In the District of Maryland, self-represented plaintiff Darrin Johnson again cited a case the court could not locate, after an earlier Rule 11 warning. Judge Rubin said the authority appeared to be hallucinated from generative AI, dismissed the action without prejudice and warned that continued use of hallucinated authorities risks sanctions.

Court
US District Court, District of Maryland
Date
2026-08-26
Who used the AI
Litigant in person
AI tool
generative AI (suspected by court)
Conduct
Self-represented plaintiff Darrin Johnson cited Cooke v. Carrington Mortgage Services, No. 22-1425 (4th Cir. 2023), which the court could not locate by caption, docket number or Westlaw citation. The court said the case appeared to be hallucinated from generative AI and warned that continued citation to hallucinated authorities risks sanctions.
Outcome
Warning
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • Cooke v. Carrington Mortg. Servs., No. 22-1425 (4th Cir. 2023), later identified as 2023 WL 3010355 — the court found no such case or matching Westlaw citation
  • Mesmer v. MAMSI Life, 377 Md. 161 (2003) — the court was unable to locate such a case but noted it preceded the Rule 11 admonition

What the court said

“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.).”
US District Court, District of Maryland, p. 30
“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.”
US District Court, District of Maryland, p. 31
“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.”
US District Court, District of Maryland, p. 31

Timeline

  1. Plaintiff initiated action in Baltimore City circuit court.
  2. Nationstar removed the action to federal court with Progressive's consent.
  3. District court dismissed the case and warned that continued hallucinated authorities risk Rule 11 sanctions.

Why this case matters

Johnson is a self-represented mortgage case where the hallucination analysis came after dismissal grounds had already resolved the action. The court had previously warned under Rule 11, then found another unlocatable Fourth Circuit mortgage case and a separate unlocatable Maryland citation. Unlike Mezu v Mezu, the court did not refer the litigant or impose money sanctions, partly because the case was being dismissed in full. The record shows how courts may preserve the sanction warning even when the false authority is not needed to decide the merits.

Practice note

A self-represented party still needs a cite-check process before filing. Search the caption, docket number, reporter citation and Westlaw citation in a legal database. Then read the case to confirm the proposition. If a party receives a Rule 11 warning, any later filing should remove authorities that cannot be independently found and should not rely on an AI tool’s case description.

Primary sources for this incident

Related regulation records for this incident

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Johnson v. Nationstar Mortgage LLC, No. 1:25-cv-00855-JRR (D. Md.)”, safelegalai.com/tracker/johnson-v-nationstar (accessed 2026-10-07). Data: CC BY 4.0.

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