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Courts on AI / Fabricated or misquoted citations

Jane Doe v. Baltimore City Board of School Commissioners

United States District Court for the District of Maryland · Federal district courts · MD · · No. SAG-23-2899 · memorandum opinion

Fabricated or misquoted citationscourt does not name AI

The District of Maryland on 2026-04-29 granted defendants’ summary-judgment motion in part, denied plaintiff’s summary-judgment motion, and refused to rely on a fabricated case in Jane Doe v. Baltimore City Board of School Commissioners. Counsel filed a reply brief with one fabricated case citation.

Disposition
Defendant’s summary-judgment motion was granted in part and denied in part, plaintiff’s motion was denied, and judgment was entered on discrimination and retaliation claims.
Recorded conduct
Plaintiff’s counsel used a fabricated quotation and citation to Nita H. v. Frederick County Public Schools. The court noted it had cause to decline considering the proposition but found the issue moot and imposed no sanction. — outcome: other; actor: lawyer
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.

(2) November 8, 2021 – Plaintiff asserts that, during her meeting with , he “stated her accommodations were being violated by ‘repeatedly giving her work with deadline demands,’” but told her that the accommodations were “‘guiding principles’to be followed only ‘tothe extent possible,’” and that she “needed to be ‘more flexible’ratherthan insisting on adherence to approved This “quote” and “citation” were one of a number of issues previously raised to Plaintiff’s counsel in this Court’s March 12, 2026 Letter Order. ECF 75. In light of the fabricated citation, this Court has sufficient cause, in its discretion, to decline to consider the proposition purportedly drawn from “Nita H. ,” for which Plaintiff cites no other case in either its cross-motion or its reply. However, the point is moot because, as discussed infra, even if this Court were to accept Plaintiff’s argument based on the fabricated citation, Plaintiff still has not adequately shown causation. Under the “intervening period” theory of causation, where “temporal proximity between protected activity and allegedly retaliatory conduct is missing, courts may look to the intervening period for other evidence of retaliatory animus.

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