Skip to content

Courts on AI / Fabricated or misquoted citations

Lafaye B. Brown v. James E. Clarke, et al.

Appellate Court of Maryland · State appellate courts · MD · · No. C-03-CV-24-004807 · order

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 rulings and noted that the appellant's reply brief used a quotation found nowhere in Maryland or other case law.
Recorded conduct
A self-represented appellant filed a reply brief using quotations that did not appear in the cited source. — 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.

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.

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