Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (1)
N.D. Illinois · Sep 3, 2025
What happened in this matter?
The court identified a 'ghost citation' in the pro se plaintiff's briefing. While the court did not impose a formal sanction, it explicitly warned that Rule 11 applies to pro se litigants and that sanctions may result from the use of non-existent case law.
- Why the court cared
- The court reasoned that the plaintiff's reliance on a non-existent case ('Lathan v. Brinkerhoff') triggered Rule 11 considerations, noting that pro se litigants are responsible for the contents of their filings and may be sanctioned for citing non-existent authorities.
- Why it matters now
- This matter connects pro se and fake citations involving implied with No sanction imposed, but noted Rule 11 may apply to pro se litigants. in N.D. Illinois, making it a concrete reference point for verification, supervision, and response controls.
Why this matter is tracked
In a Fair Housing Act and Civil Rights Act suit, the pro se plaintiff, Steven E. Hobbs, Sr., cited 'Lathan v. Brinkerhoff' in his opposition to a motion to dismiss. The court and defense counsel were unable to locate the cited case, identifying it as a 'ghost citation.' The court noted that Federal Rule of Civil Procedure 11 applies to pro se litigants and that sanctions may result from such conduct, particularly if the citation was not merely a typographical error but a reference to a non-existent case. The court ultimately dismissed several of the plaintiff's claims against the defendants, Coldwell Banker and property owners Goncharko and 5120 South LLC, for failure to state a claim.
This matter connects pro se and fake citations involving implied with No sanction imposed, but noted Rule 11 may apply to pro se litigants. in N.D. Illinois, making it a concrete reference point for verification, supervision, and response controls.
Record details
What the record establishes about AI use
implied is recorded in the source dataset; confirm the basis in the linked document.
Memorandum Opinion and Order resolving motions to dismiss filed by defendants under Federal Rule of Civil Procedure 12(b)(6).
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.
- Fabricated: Case Law | Pro se plaintiff cited 'Lathan v. Brinkerhoff' in briefing; court and defense counsel could not locate the case and called it a ghost citation.
Questions this record answers
- What happened in Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (1)?
- The court identified a 'ghost citation' in the pro se plaintiff's briefing. While the court did not impose a formal sanction, it explicitly warned that Rule 11 applies to pro se litigants and that sanctions may result from the use of non-existent case law.
- Why does Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (1) matter for legal AI risk?
- This matter connects pro se and fake citations involving implied with No sanction imposed, but noted Rule 11 may apply to pro se litigants. in N.D. Illinois, making it a concrete reference point for verification, supervision, and response controls.
- What does the public record establish about Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (1)?
- 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.
- Which source supports this Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (1) 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.