Darrin L. Johnson, Jr. v. Nationstar Mortgage, LLC, et al.
D. Maryland · Apr 30, 2026 · Julie R. Rubin
- Jurisdiction
- federal
- Court
- D. Maryland
- Record ID
- darrin-l-johnson-jr-v-nationstar-mortgage-llc-et-al-2026-04-30
- Observed outcome
- Motion for preliminary injunction denied; formal judicial admonition issued regarding AI-generated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court denied the plaintiff's motion for a preliminary injunction and issued a formal admonition regarding the use of AI-generated, hallucinated legal citations. The court explicitly warned that future filings containing fabricated authorities may result in an order to show cause why Rule 11 sanctions should not be imposed.
The court reasoned that while pro se litigants are granted latitude, they remain accountable for the accuracy of their filings under Rule 11. The court determined that the cited case did not exist in the Westlaw database and concluded it was likely the product of AI hallucination. The court exercised its discretion to issue a warning rather than an immediate show cause order, citing the need for extra care in sua sponte sanctions.
This case illustrates judicial oversight of pro se filings involving AI-generated hallucinations. It highlights the court's preference for issuing formal warnings to pro se litigants regarding citation accuracy before escalating to formal Rule 11 show cause proceedings.
Failure modes and consequences
- Pro Se
- Fake Citations
- Contract
- Trial
- Ordered To Show Cause
- AI attribution
- Implied
- Recorded tool
- Generative artificial intelligence (e.g., ChatGPT, Gemini, etc.)
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum Opinion and Order denying Plaintiff's Motion for Preliminary Injunction.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court identified the citation as likely derived from generative AI tools.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.