⚡ CASE DIGEST
Hobbs v. Goncharko et al. — N.D. Illinois, 16 January 2026
Pro se plaintiff Steven Hobbs brought Fair Housing Act claims against his landlords in Chicago but submitted filings citing non-existent cases. Judge Lindsay Jenkins granted defendants’ motion to dismiss Coldwell Banker’s claims while allowing some landlord-related claims to proceed.
Why it matters: Non-existent case citations are appearing even in Fair Housing cases brought by self-represented litigants. Courts are noting these hallucinations in published opinions regardless of whether the filer is an attorney.
Category: Hallucinations & Sanctions | Jurisdiction: USA | Read time: 5 min
Case at a Glance
| Full Citation | Hobbs v. Goncharko et al., No. 25 CV 3398 (N.D. Ill.) |
| Court | United States District Court, Northern District of Illinois, Eastern Division |
| Date of Decision | 16 January 2026 |
| Category | AI Hallucinations & Sanctions |
| Jurisdiction | USA |
| AI Tool Used | Not specified (non-existent case citations noted) |
| Judgment / Order | CourtListener / Westlaw |
Background
Steven Hobbs, Sr., an African American man, was evicted from his Chicago apartment and brought racial discrimination, disability discrimination, and retaliation claims under the Fair Housing Act against Coldwell Banker (his leasing agent) and his landlords Igor Goncharko and 5120 South LLC. The court had previously dismissed some claims with leave to amend, and Hobbs filed an amended complaint. His submissions, filed pro se, contained references to cases that the court identified as non-existent.
The AI Issue
The court had to assess Hobbs’s amended Fair Housing claims while also dealing with filings that cited case law that did not exist. The legal question was whether any of the remaining claims — racial discrimination and disability discrimination against the landlord defendants — were adequately pleaded, notwithstanding the defective citations.
What the Court Decided
- Coldwell Banker’s motion to dismiss was granted in full — the retaliation and disability claims against the real estate agent failed [insufficient pleading].
- Landlord Defendants’ joint motion to dismiss was denied — race and disability discrimination claims against Igor Goncharko survived [plausible claims].
- The court’s opinion flagged non-existent citations as part of the published record [AI hallucination documented].
- Pro se status did not excuse the submission of non-existent authority, though the court adjudicated the merits regardless.
Key Quote
The court noted that citations in petitioner’s briefing referred to cases that appeared to be hallucinations, requiring additional verification before they could be relied upon.
— Judge Lindsay C. Jenkins, N.D. Illinois, 16 January 2026
The India Angle
Indian Law Equivalent: Indian courts have not yet imposed AI-specific sanctions, but the duty of verification is embedded in Rule 15 of the Bar Council of India Rules (duty not to mislead the court) and the Contempt of Courts Act, 1971. Fabricated citations — whether AI-generated or otherwise — would constitute contempt before any Indian court.
Bar Council Rules: Bar Council of India Rule 15 requires advocates not to mislead the court. Submitting an AI-generated citation without verification is a clear breach. Disciplinary proceedings before the State Bar Council could follow, including suspension or removal from the roll.
Practical Advice for Indian Advocates: Verify every AI-generated case citation on SCC Online, Manupatra, or IndianKanoon before filing. Never rely on a citation you have not personally confirmed exists and says what the AI claims it says. AI hallucinations are a global phenomenon and Indian courts will follow the same enforcement trajectory.
Quick Takeaways
- Non-existent case citations are now being flagged by courts even in pro se filings — no special treatment for self-represented litigants.
- Fair Housing and civil rights claims can proceed on their merits even when some cited authorities are hallucinated — but the fabricated citations remain on the record.
- Advocates assisting pro se litigants must verify all citations before submission, as the duty of verification is not relaxed for laypersons.