District of Maryland Hallucination Decision

Because I practice in Maryland, I attempt to keep track of Maryland “hallucination” decisions. Johnson v. Nationstar Mortgage LLC, 2026 WL 2516390 (D. Md. Aug. 26, 2026), is a recent one.

The Court had squarely warned plaintiff that Fed.R.Civ.P. 11 applied to unrepresented parties and attorneys in the context of “hallucinated” citations.  Plaintiff apparently did not heed the warning.  However, plaintiff escaped sanctions because his case was dismissed on other grounds.

The Court wrote:

Notwithstanding the foregoing admonition, it appears Plaintiff has once again cited a “hallucinated” case derived perhaps from use of a generative artificial intelligence (“AI”) tool (e.g., ChatGPT, Gemini, etc.). Specifically, Plaintiff cites to “Cooke v. Carrington Mortg. Servs., No. 22-1425 (4th Cir. 2023),”…. Plaintiff contends this case stands for the proposition that “servicer-imposed charges tied to improper insurance placement constitute a concrete injury.” … Upon challenge by Nationstar, Plaintiff later represented once again that “Cooke v. Carrington Mortg. Servs., No. 22-1425 (4th Cir. 2023)” is an “unpublished case” available at “2023 WL 3010355.” … Based on the court’s review, this case does not exist. The court has checked the Fourth Circuit case number—22-1425, and Westlaw citation—2023 WL 3010355—offered by Plaintiff to identify this case; neither directs the court to the referenced opinion. Indeed, the court further observes two decisions of this court bearing this caption: Cooke v. Carrington Mortg. Servs., No. CV TDC-18-0205, 2019 WL 3241128, at *1 (D. Md. July 18, 2019), and Cooke v. Carrington Mortg. Servs., No. CV TDC-18-0205, 2018 WL 6323116, at *7 (D. Md. Dec. 3, 2018)—neither of which pertains to “improper insurance placement.”

While this court has already cautioned Plaintiff that continued citation to hallucinated authorities or the like risks issuance of an order to show cause why he should not face sanctions under Rule 11, the court declines to take further action in the instant matter where Plaintiff’s case will be dismissed in full. [emphasis added].

For more District of Maryland AI decisions, please use the “category” District of Maryland, above.  For example, please see A.I. Protective Orders Are Becoming Routine (Aug. 27, 2026), District of Maryland “Hallucination” Decision (May 5, 2026), and District of MD Standing Order re GenAI in Court Filings (Aug. 10, 2026).

For Maryland State court decisions, please see Maryland Copy and Paste “Hallucinations” Case – (Jun. 17, 2026), Hallucinations Are “Old News,” But a Recent Maryland Decision Addresses Ethical Contours (Jan. 17, 2025), Maryland Fake Citation Case – Court Issues a Warning – Referral to Atty. Grievance Comm’n. (Nov. 2, 2025), and Maryland’s Proposed Anti-Hallucination Rule (Mar. 16, 2026).

UPDATE: Aziz v. USA, 2026 WL 2633445 (D. Md. Sep. 4, 2026)(Abelson, J.)(“The Court warned Plaintiffs about their high-volume approach in its previous opinion: ‘If Plaintiffs continue to file frivolous motions or include fabricated citations, and/or violate the [four-]page limitation set forth in the accompanying order, the Court may enjoin them from submitting further filings or consider imposing other sanctions.’ Aziz, 2026 WL 1132884 at *3. As a review of the docket will indicate, Plaintiffs did not heed this warning, and have continued filing numerous motions. Many of these filings were over four pages, included hallucinated or fabricated citations, and contained frivolous arguments that misstated the law and/or facts. See, e.g., ECF No. 114 (‘Plaintiff’s Emergency Motion to Compel Ruling on Pending § 1292(b) Motion; For Stay; And For Reconsideration of Orders Entered Without Jurisdiction’). The Court has nonetheless reviewed these motions and will deny all of them as either moot in light of the instant dismissal or denied for the reasons provided in the previous memorandum opinions. The Court will not issue an order to show cause regarding sanctions because it is dismissing this case. However, Plaintiffs are forewarned that similar conduct in this case or others may result in sanctions.”).