Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (2)
N.D. Illinois · Jan 16, 2026
What happened in this matter?
The court issued a formal warning to the pro se plaintiff regarding the inclusion of hallucinated and mis-cited case law in his filings. While the court declined to impose immediate sanctions, it explicitly cautioned that future submissions containing such errors could result in dismissal of the case with prejudice.
- Why the court cared
- Fabricated: Case Law | Plaintiff twice cited a non-existent case Lathan v. Brinkerhoff; court identified it as fictitious and previously warned about it. || Fabricated: Case Law | Plaintiff mis-cited 'City of Chicago v. Matchmaker' (court treated it as an incorrect/fictitious citation in plaintiff's brief). || Fabricated: Case Law | Plaintiff cited 'Oconomowoc v. Greenfield,' a mis-citation distinct from the real Oconomowoc Residential Programs precedent referenced by the court. || Fabricated: Case Law | Plaintiff cited 'Vargas v. Cook Cnty. Sheriff' in his brief; court listed it among the mis-citations in the response. || Misrepresented: Case Law | Plaintiff invoked Bloch v. Frischholz for the proposition that statistical evidence is not required; court explained Bloch does not support that conclusion and was misrepresented.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in N.D. Illinois, with the listed outcome: Warning.
Why this matter is tracked
In a Fair Housing Act case, the pro se plaintiff repeatedly included hallucinated legal citations in his response brief, despite a prior court warning regarding the same conduct. Specifically, the plaintiff cited a fictitious case, 'Lathan v. Brinkerhoff,' and mis-cited several other authorities, including 'City of Chicago v. Matchmaker,' 'Oconomowoc v. Greenfield,' and 'Vargas v. Cook Cnty. Sheriff.' Additionally, the plaintiff misrepresented the holding of 'Bloch v. Frischholz.' The court identified these errors as fictitious or incorrect and explicitly warned the plaintiff that future submissions containing hallucinated citations could result in sanctions, including dismissal with prejudice. The court ultimately denied the Landlord Defendants' motion to dismiss on the merits while granting the motion of another defendant.
This record documents a Pro Se Litigant filing issue in N.D. Illinois, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court refers to the plaintiff's conduct as hallucinating citations.
Memorandum Opinion and Order on defendants' motions to dismiss the plaintiff's second amended complaint.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff twice cited a non-existent case Lathan v. Brinkerhoff; court identified it as fictitious and previously warned about it.
- Fabricated: Case Law | Plaintiff mis-cited 'City of Chicago v. Matchmaker' (court treated it as an incorrect/fictitious citation in plaintiff's brief).
- Fabricated: Case Law | Plaintiff cited 'Oconomowoc v. Greenfield,' a mis-citation distinct from the real Oconomowoc Residential Programs precedent referenced by the court.
- Fabricated: Case Law | Plaintiff cited 'Vargas v. Cook Cnty. Sheriff' in his brief; court listed it among the mis-citations in the response.
- Misrepresented: Case Law | Plaintiff invoked Bloch v. Frischholz for the proposition that statistical evidence is not required; court explained Bloch does not support that conclusion and was misrepresented.
Questions this record answers
- What happened in Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (2)?
- The court issued a formal warning to the pro se plaintiff regarding the inclusion of hallucinated and mis-cited case law in his filings. While the court declined to impose immediate sanctions, it explicitly cautioned that future submissions containing such errors could result in dismissal of the case with prejudice.
- Why does Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (2) matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in N.D. Illinois, with the listed outcome: Warning.
- What does the public record establish about Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (2)?
- 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 Steven E. Hobbs, Sr. v. Igor Goncharko, et al. (2) 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.