The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Docket entry 72, 26 August 2026 · source · PDF · 32 pages
Docket text. MEMORANDUM OPINION. Signed by Judge Julie Rebecca Rubin on 8/26/2026. (dass, Deputy Clerk) (c/nef)
The court will grant Nationstar’s Motion and dismiss Plaintiff’s quiet title claim.27 IV. CITATION TO HALLUCINATED AUTHORITY In this court’s ruling on Plaintiff’s motion for preliminary injunction, it commended to Plaintiff’s attention Federal Rule of Civil Procedure 11. Specifically, the court advised: Federal Rule of Civil Procedure 11 requires unrepresented parties and attorneys “to certify, on the basis of a reasonable inquiry, that any pleading or paper they file with a district court (1) is not filed ‘for any improper purpose’; (2) is ‘warranted by existing law’; and (3) alleges facts that ‘have evidentiary support.’” Lokhova v.
To be sanctionable, a legal argument must have “absolutely no chance of success under the existing precedent.” Hunter, 281 F.3d at 153. “Courts within the Fourth Circuit have issued sua sponte show cause orders where a party appears to have ‘cited to fictitious cases and misrepresented the holding of various cases’ in a filing.” Neal v. Frayer, No.
68 at pp. 7–8.) Notwithstanding the foregoing admonition, it appears Plaintiff has once again cited a “hallucinated” case derived perha ps from use of a generative artificial intelligence (“AI”) tool (e.g., ChatGPT, Gemini, etc.). 28 Specifically, Plaintiff cites to “Cooke v.
Carrington Mortg. 28 “Fake or nonexistent legal citations typically are the result of AI ‘hallucinations.’” Mezu v. Mezu , 267 Md.
62 at p. 1.) 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.
Dec. 3, 2018)—neither of which pertains to “improper insurance placement.” 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. V.
Docket entry 68, 30 April 2026 · source · PDF · 9 pages
Docket text. MEMORANDUM AND ORDER denying Plaintiff's 64 Motion for Preliminary Injunction. Signed by Judge Julie Rebecca Rubin on 4/30/2026. (dass, Deputy Clerk) (c/nef)
2 IV. ADMONITION CONCERNING CITATION OF HALLUCINATED AUTHORITY As an unrelated matter, upon review of Plaintiff’s filings, the court was unable to locate the following case cited in Plaintiff’s Motion and reply in support of same: Jefferson v. U.S.
The court notes that, when entered into the Westlaw database, the citation provided by Plaintiff yields no results. It appears the citation may be a “hallucinated” case citation derived from the use of a generative artificial intelligence (“AI”) tool (e.g., ChatGPT, Gemini, etc.).3 Federal Rule of Civil Procedure 11 requires unrepresented parties and attorneys “to certify, on the basis of a reasonable inquiry, that any pleading or paper they file with a district court (1) is not filed ‘for any improper purpose’; (2) is ‘warranted by existing law’; and (3) alleges facts that ‘have evidentiary support.’” Lokhova v. Halper, 30 F.4th 349, 354 (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.
8 must have “absolutely no chance of success under the existing precedent.” Hunter , 281 F.3d at 153. “Courts within the Fourth Circuit have issued sua sponte show cause orders where a party appears to have ‘ cited to fictitious cases and misrepresented the holding of various cases ’ in a filing.” Neal v. Frayer, No.
Sept. 19, 2025) (“While the Court affords pro se litigants substantial latitude in their filings, that does not provide permission to include nonexistent quotations and citations. In particular, when using generative artificial intelligence, litigants must be aware ‘that such platforms sometimes ‘hallucinate,’ meaning they provide inaccurate responses.’”) (quoting Kruglyak v.
27, 2026). While Plaintiff here appears to have cited only one hallucinated case in his Motion papers, the court cautions Plaintiff (and the parties more generally) regarding use of generative AI tools in legal filings. In this discrete instance, the court will not issue a Rule 11 show cause order as to Plaintiff’s citation to a hallucinated case.
In this discrete instance, the court will not issue a Rule 11 show cause order as to Plaintiff’s citation to a hallucinated case. Nevertheless , Plaintiff is strongly cautioned: should he engage in similar conduct in the future (i.e ., citation to hallucinated authorities or the like), the court may exercise its discretion to issue an order to show cause why he should not face sanctions under Rule 11. V.