Courts on AI / Fabricated or misquoted citations

Dorsey v. Livramento

Appellate Court of Maryland · State appellate courts · MD · 2026-05-20 · 2026 WL 1452427 · No. No. 2237, September Term, 2025 · opinion

Fabricated or misquoted citations

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 custody order was affirmed, costs were assessed to appellant, and the court warned that continued citation of fabricated or misrepresented authorities may result in sanctions or referral.
Recorded conduct: Mother’s brief contained numerous fictitious cases and misrepresented legal authorities, including several nonexistent Maryland cases identified in footnotes. The court suspected use of generative AI and warned that future fake citations may lead to sanctions or referral. — 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)

Court document: mdcourts.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. Official copy located 2026-09-08 at www.mdcourts.gov; quoted passage confirmed. Re-coded from the document 2026-09-08 (independent second read).

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