Courts on AI / Fabricated or misquoted citations
Brown v. Clarke
Appellate Court of Maryland · State appellate courts · MD · · No. No. 1448 · opinion
On 2026-06-04, in Lafaye B. Brown v. James E. Clarke, et al, Appellate Court of Maryland affirmed the foreclosure rulings and noted that the appellant's reply brief used a quotation found nowhere in Maryland or other case law. A self-represented appellant filed a reply brief using quotations that did not appear in the cited source.
- Disposition
- The court affirmed the foreclosure judgment and costs without imposing any consequence for the false Brock quotation.
- Recorded conduct
- Brown’s reply brief attributed a parenthetical quotation to Brock that the court could not find in Brock, any Maryland case, or any case. The court affirmed and imposed no consequence for the citation issue. — outcome: noted, no consequence; 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.
at 728. As a result, the Substitute Trustees have standing to foreclose. Thus, Brown’s motion to stay or dismiss did not raise a valid defense to the Substitute Trustees’ right to foreclose, and the circuit court therefore did not abuse its discretion in denying it without a hearing. JUDGMENT OF THE CIRCUIT COURT FOR BALTIMORE COUNTY AFFIRMED. COSTS TO BE PAID BY APPELLANT. In her reply brief, Brown cites to Brock, 430 Md. at 729 with a parenthetical quote: “production of a copy of the note does not prove possession of the original[.]” This quote does not appear in Brock, any other Maryland case, or, indeed, any case anywhere.
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