Marques Johnson v. Capital One Financial Corporation
E.D. Michigan · Nov 10, 2025
What happened in this matter?
The magistrate judge identified a likely AI-generated hallucination in the plaintiff's filing, specifically a fabricated quotation attributed to Cohen v. Cap. One Funding, LLC. The court flagged this as part of an ongoing issue with generative AI in litigation and recommended dismissal of the plaintiff's claims on the merits.
- Why the court cared
- False Quotes: Case Law | Plaintiff cited Cohen v. Cap. One Funding, LLC and attributed a quotation—"Receivables are pooled and sold monthly."—to that opinion and misidentified the issuing court; the magistrate judge found the alleged quote does not appear in the Cohen decision and flagged it as likely an AI-generated hallucination.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in E.D. Michigan, with the listed outcome: no adjudicated outcome recorded.
Why this matter is tracked
In a pro se action against Capital One, the plaintiff alleged that his credit application constituted a monetizable receivable and that his subsequent typewritten submissions served as valid legal tender to discharge his debt. In support of these claims, the plaintiff cited Cohen v. Cap. One Funding, LLC, 489 F. Supp. 3d 33 (E.D.N.Y. 2020), misidentifying the issuing court and attributing a quotation regarding the pooling and sale of receivables to the opinion. The magistrate judge noted that the purported quote does not appear in the Cohen decision and identified the citation as a likely hallucination generated by artificial intelligence. The court recommended granting the defendant's motion to dismiss, characterizing the plaintiff's underlying legal theories as frivolous.
This record documents a Pro Se Litigant filing issue in E.D. Michigan, with the listed outcome: no adjudicated outcome recorded.
Record details
What the record establishes about AI use
The court explicitly mentions the use of generative artificial intelligence as the source of the hallucinated citation.
Report and Recommendation to grant Defendant's motion to dismiss.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Plaintiff cited Cohen v. Cap. One Funding, LLC and attributed a quotation—"Receivables are pooled and sold monthly."—to that opinion and misidentified the issuing court; the magistrate judge found the alleged quote does not appear in the Cohen decision and flagged it as likely an AI-generated hallucination.
Questions this record answers
- What happened in Marques Johnson v. Capital One Financial Corporation?
- The magistrate judge identified a likely AI-generated hallucination in the plaintiff's filing, specifically a fabricated quotation attributed to Cohen v. Cap. One Funding, LLC. The court flagged this as part of an ongoing issue with generative AI in litigation and recommended dismissal of the plaintiff's claims on the merits.
- Why does Marques Johnson v. Capital One Financial Corporation matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in E.D. Michigan, with the listed outcome: no adjudicated outcome recorded.
- What does the public record establish about Marques Johnson v. Capital One Financial Corporation?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Marques Johnson v. Capital One Financial Corporation summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.