Courts on AI / Fabricated or misquoted citations
Eyong v. 72 Barrow St. Realty Corp.
Appellate Court of Maryland · State appellate courts · MD · · 2026 WL 2321382 · No. 1910, Sept. Term, 2025 · opinion
The Appellate Court of Maryland affirms judgment for 72 Barrow St. Realty and taxes costs to Simon Eyong. The per curiam opinion notes earlier orders striking large portions of his self-represented briefs for fictitious legal citations and inaccurate summaries, and leaves a sanctions motion for remand.
- Disposition
- The court affirmed judgment for the landlord, taxed costs to appellant, and noted a remand sanctions motion could be considered.
- Recorded conduct
- Self-represented appellant’s opening and reply briefs contained fictitious legal citations and inaccurate summaries of case holdings. — outcome: costs order; actor: litigant in person
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
72 Barrow has moved for sanctions against Mr. Eyong under Rules 1-341 and 8-504, arguing that his citation to fictional legal authority in his opening brief and his reply brief; the lack of legal authority for his positions; and his failure to prepare a record extract justify an award of reasonable attorneys’ fees and costs. On remand, the circuit court may entertain a motion under Rule 1-341(a) concerning fees incurred by 72 Barrow in defending this appeal. ... JUDGMENT OF THE CIRCUIT COURT FOR MONTGOMERY COUNTY AFFIRMED. COSTS TO BE PAID BY APPELLANT. ... This Court previously entered an order striking large portions of Mr. Eyong's opening brief and his reply brief because it contained fictitious citations to legal authority and inaccurate summaries of the holdings of other cases. We limit our consideration of the issues to the portions of the briefs that have not been stricken.
Authorities cited in the passage: Md. Rule 1-341 · Md. Rule 8-504 · Litty v. Becker, 104 Md. App. 370 (1995)
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