University Mall, LLC v. Okorie
U.S. District Court, Southern District of Mississippi · S.D. Miss. · Mississippi bar guidance
Conduct
Pro se vexatious litigant in a post-foreclosure detainer action did not dispute using AI to generate pleadings that contained multiple hallucinated citations.
Consequence
Compensatory civil contempt sanctions plus a Fifth-Circuit-wide pre-filing injunction; the AI-citation findings supported the vexatious-litigant analysis.
Lesson
AI-hallucinated citations can become evidence in a vexatious-litigant analysis, compounding a pro se filer's exposure to a pre-filing injunction.
Verified May 14, 2026
- Citation
- University Mall, LLC v. Okorie, No. 2:24-cv-91-KS-MTP (S.D. Miss. Oct. 22, 2025) (Starrett, J.)
- Decided
- October 22, 2025
Summary
Ikechukwu Okorie is a defendant in a post-foreclosure detainer action brought by University Mall, LLC in the Southern District of Mississippi (No. 2:24-cv-91-KS-MTP), arising from his refusal to vacate a Hattiesburg building after it sold at foreclosure. On October 22, 2025, District Judge Keith Starrett granted University Mall's motion for civil contempt and motion for a pre-filing injunction. In analyzing Okorie's vexatious-litigation history, the court found that Okorie does not dispute using artificial intelligence to generate his pleadings, and that his filings in this action contained multiple instances of AI "hallucinated" citations to cases and rulings that do not exist, along with non-existent rulings and quotes attributed to real cases. The court noted it had already admonished or sanctioned Okorie for hallucinated citations in other civil actions and in his related bankruptcy case (In re Okorie, No. 19-50379-KMS).
- AI tool:
- Implied (specific tool not identified; court found Okorie uses AI to generate his pleadings)
What sanction did the court impose?
Motion for contempt and motion for pre-filing injunction granted. The court imposed compensatory civil contempt sanctions, including $85,260.87 in per diem rent, reimbursement of moving and storage costs, and attorney's fees, and entered a pre-filing injunction barring Okorie from filing new cases in the federal courts of the Fifth Circuit and the state courts of Mississippi and Texas without first obtaining leave of court. The AI-citation findings were part of the vexatious-litigant analysis supporting the injunction.
Why does University Mall, LLC v. Okorie matter for law firms using AI?
University Mall, LLC v. Okorie is an October 22, 2025 District Court order (Judge Keith Starrett, S.D. Miss.) granting a motion for civil contempt and a motion for a pre-filing injunction against Ikechukwu Okorie, a pro se defendant in a post-foreclosure detainer action. The AI issue is one thread in a broader vexatious-litigant analysis: the court found that Okorie does not dispute using artificial intelligence to generate his pleadings, and that his filings in this action contained multiple hallucinated citations to non-existent cases and rulings, as well as fabricated quotes attributed to real cases. The court had already admonished or sanctioned Okorie for hallucinated citations in other civil actions and in his related bankruptcy case (In re Okorie, No. 19-50379-KMS). The order imposes compensatory contempt sanctions and a pre-filing injunction reaching the federal courts of the Fifth Circuit and the state courts of Mississippi and Texas.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- When opposing a repeat pro se filer, AI-hallucinated citations are not just a candor problem: courts are folding them into the vexatious-litigation factors that support pre-filing injunctions.
- Cross-reference a litigant's filings across cases: the court here cited hallucinated-citation admonitions from Okorie's other civil actions and his related bankruptcy case (In re Okorie, No. 19-50379-KMS) to establish a pattern.