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Courts on AI / Fabricated or misquoted citations

Fatima Meziane v. Abdelouahab Aitouche

Appellate Court of Maryland · State appellate courts · MD · · 2026 WL 1101776 · No. C-15- FM-23-003513 Berger, Friedman, Sharer, J. Frederick · opinion

Fabricated or misquoted citations

The Appellate Court of Maryland on 2026-04-23 affirmed the custody judgment, assessed costs to the appellant, and exercised discretion not to strike a brief with fictitious citations in Fatima Meziane v. Abdelouahab Aitouche. The self-represented appellant filed a brief with two fabricated case citations, including Hurd v. Hurd.

Disposition
The court affirmed the custody judgment, assessed costs to the appellant, and exercised discretion not to strike a brief with fictitious citations.
Recorded conduct
The self-represented appellant filed a brief with two fabricated case citations, including Hurd v. Hurd and Bradley v. Bradley. — outcome: other; 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.

” In support, she cites In re Yves S. , 373 Md. 551, 586–87 (2003) and Karanikas v. Cartwright, 209 Md. App. 571, 589–90 (2013). Neither of these cases support the stated proposition. To be sure, citations of inapposite authority is not uncommon in pro se filings, and, alone, it does not necessarily indicate the use of AI, but Mother's principal brief also contains two apparently fictitious citations: • Hurd v. Hurd, 223 Md. App. 654, 667–68 (2015), see Appellant's Br. at 13, does not exist. There is no Maryland case bearing this caption, and the principal cite leads to Assateague Coastal Tr. , Inc. v. Schwalbach, 223 Md.

Authorities cited in the passage: Karanikas v. Cartwright, 209 Md · Hurd v. Hurd, 223 Md · Inc. v. Schwalbach, 223 Md · Maryland case 'Hurd v. Hurd, 223 Md. App. 654, 667–68 (2015)' · Maryland case 'Bradley v. Bradley, 174 Md. App. 234, 248–50 (2007)'

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