Courts on AI / Fabricated or misquoted citations
Ali Behroz Aziz v. United States of America
United States District Court for the District of Maryland · Federal district courts · MD · · No. 26-cv-243-ABA · memorandum opinion
The District of Maryland on 2026-04-27 imposed page limits and warned the self-represented plaintiffs after identifying a nonexistent forfeiture case citation in Ali Behroz Aziz, et al. v. United States of America, et al. The self-represented plaintiff filed a motion with one fabricated case citation, including United States v. $17,900 in U.S. Currency.
- Disposition
- All pending motions were denied except leave to amend was reserved, page limits were imposed, and plaintiffs were warned about fabricated citations and frivolous filings.
- Recorded conduct
- Plaintiffs filed numerous motions with hallucinated cases and citations, including a nonexistent United States v. $17,900 in U.S. Currency quote. The court found likely AI use and warned of sanctions or a filing injunction. — 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.
53–55, 56–58) comprising over 40 pages of coherent legal analysis all on April 10, 2026, the day after the Court’s prior order, ECF No. 52. The latest flurry worsens a pattern of repeated filings: the Court’s previous order denied four of Plaintiffs’ motions that were filed within the space of a few weeks. ECF No. 52. The likeliest explanation is that Plaintiffs are using an artificial intelligence (AI) tool. This inference is further corroborated by numerous hallucinated cases and citations: for example, in ECF No. 59 at 8, Plaintiffs’ quote a previous case of this Court (“United States v. $17,900 in U. S. Currency”) that does not appear to exist. Although the use of AI tools for legal research or drafting is not inherently improper, Plaintiffs’ avalanche of filings here, whether AI-generated or not, have burdened the Court, advanced frivolous arguments, misstated the record, and fabricated legal authorities.