Victor Kholod v. Nationstar Mortgage LLC
M.D. Pennsylvania · Jul 22, 2025
- Jurisdiction
- federal
- Court
- M.D. Pennsylvania
- Record ID
- victor-kholod-v-nationstar-mortgage-llc-2025-07-22
- Observed outcome
- The court recommended granting the defendants' motions to dismiss with leave to amend and issued a formal warning regarding the use of fictitious case law.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to the pro se plaintiff regarding the submission of fictitious case law, likely generated by AI. The magistrate judge recommended dismissal of the complaint with leave to amend, cautioning that future reliance on fabricated authorities could trigger Rule 11 sanctions.
The court reasoned that the plaintiff's citations were either non-existent or factually unrelated to the claims, and that the use of such fictitious material violates the standards of practice, warranting a warning under Rule 11.
This case highlights the judiciary's increasing scrutiny of AI-generated 'hallucinations' in pro se filings. It serves as a precedent for courts issuing formal warnings to litigants who fail to verify the existence and relevance of cited authorities.
Failure modes and consequences
- Pro Se
- Fake Citations
- Misrepresented Authority
- Published Opinion
- Contract
- Trial
- AI attribution
- Implied
- Recorded tool
- Generative Artificial Intelligence (GAI) tools, such as ChatGPT
- Known monetary consequence
- Not recorded
- Procedural posture
- Report and Recommendation on motions to dismiss filed by defendants, recommending dismissal with leave to amend.
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 GAI tools like ChatGPT as the source of the fictitious cases.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- 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.