Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (1)
N.D. Illinois · Sep 3, 2025
- Jurisdiction
- federal
- Court
- N.D. Illinois
- Record ID
- steven-e-hobbs-sr-v-igor-goncharko-et-al-1-2025-09-03
- Observed outcome
- No formal sanction was imposed, but the court issued a warning regarding Rule 11 obligations for pro se litigants.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Hallucinated_case_law
- Pro Se
- Fake Citations
- Civil Rights
- Trial
- None Adjudicated
- AI attribution
- Implied
- Recorded tool
- implied
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum Opinion and Order resolving motions to dismiss filed by defendants under Federal Rule of Civil Procedure 12(b)(6).
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
implied is recorded in the source dataset; confirm the basis in the linked document.
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 implied output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.