Incident Tracker / United States (federal)
Turgeon v. FHLMC, No. 1:25-cv-00510-SM-TSM (D.N.H.)
·US District Court, District of New Hampshire·US-FEDOther
In the District of New Hampshire, self-represented debtor Noella Turgeon appealed a bankruptcy order that struck her objection after false, hallucinated citations. Judge McAuliffe held the bankruptcy court acted within its discretion, affirmed the order, and left the struck objection in place without imposing a separate monetary sanction.
- Court
- US District Court, District of New Hampshire
- Date
- 2026-08-26
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Self-represented debtor Noella Turgeon appealed after the bankruptcy court struck her objection for false, hallucinated case citations. The district court held the bankruptcy court acted within its discretion, affirmed the order, and left the struck objection in place without adding a separate monetary sanction.
- Outcome
- Other
- 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
- False, hallucinated case citations in Turgeon's objection to the trustee's motion to dismiss — the bankruptcy court said the cases either did not exist, came from a different court than cited, or did not support the propositions asserted; the order did not list them
What the court said
“The court then questioned Turgeon regarding her Objection to the Trustee’s motion to dismiss. Specifically, the court asked Turgeon about her use of “false, hallucinated case citations” within her brief.”
“Accordingly, her objection to the motion to dismiss would be stricken.”
“The bankruptcy court even took the time to explain to Turgeon why the cases she had cited in her objection were misleading, clarifying for her that the cases she had cited either did not exist, were issued by a different court than the court Turgeon had cited, or simply did not stand for the propositions for which Turgeon had cited them.”
“For the foregoing reasons, the decision of the bankruptcy court dismissing Turgeon’s Chapter 13 petition is affirmed.”
Timeline
- Turgeon filed a second Chapter 13 petition.
- Bankruptcy court struck her objection after questioning false, hallucinated case citations.
- Bankruptcy court dismissed the petition and declined jurisdiction over remaining matters.
- District court affirmed the bankruptcy court’s dismissal.
Why this case matters
Turgeon adds a bankruptcy-procedure setting to the tracker. The false citations were not the sole reason the case ended; the district court also relied on missed plan, notice, service and payment requirements. That makes it different from Huish v HMRC, where the tribunal recorded a litigant-in-person AI problem but still allowed the appeal on the merits. Here the sanction-like step was targeted: the objection was struck, leave to amend was offered, and the later appeal failed when the debtor did not use that chance.
Practice note
When a bankruptcy court flags authorities as false or misleading and gives leave to amend, the safe response is to refile by the deadline with only verified citations. Each case should be checked in an official database for caption, court, date and holding. If a citation cannot be verified, remove it and explain the remaining argument from the Bankruptcy Code, rules and record.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Turgeon v. FHLMC, No. 1:25-cv-00510-SM-TSM (D.N.H.)”, safelegalai.com/tracker/turgeon-v-fhlmc (accessed 2026-10-07). Data: CC BY 4.0.