Skip to content

Courts on AI / Fabricated or misquoted citations

Brandy Dorsey v. Walter Livramento, III

Appellate Court of Maryland · State appellate courts · MD · · 2026 WL 1413152 · No. 2237 September Term, 2025 · order

Fabricated or misquoted citationsGAI

On 2026-05-20, in Brandy Dorsey v. Walter Livramento, III, Appellate Court of Maryland warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed a brief using numerous nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Disposition
The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
A self-represented appellant filed a brief using numerous nonexistent or hallucinated authorities and authorities used for propositions they did not support. — outcome: warning; 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.

Submission of nonexistent or inaccurate legal authority is improper and wastes judicial resources. Mother's brief contains numerous citations to cases and other legal authorities. We suspect that Mother may have used generative artificial intelligence (“AI”) to assist in drafting her brief, as several cited authorities are fictitious, and others do not support the stated proposition.5 We identify these problematic citations in footnotes as relevant. In Mezu v. Mezu, 267 Md. App. 354 (2025), we highlighted the potential dangers of using AI to conduct legal research or generatefilings,includingtheriskof“hallucinated”citations. Id. at 367–68. Moreover, “[t]he citation of fake cases in a brief or other pleading filed with a court implicates multiple Maryland Rules.” Id. at 368. Attorneys who submit filings containing fake citations may be referred to the Attorney Grievance Commission depending on the nature and severity of the misconduct. See id. at 374. Although there is no parallel disciplinary action for pro se litigants, Maryland Rule 1-311(c) authorizes us to strike the offending filing.

Authorities cited in the passage: In Mezu v. Mezu, 267 Md · Rule 1-311(c)

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub