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Regulation Tracker / United States (state)

Mezu v. Mezu, No. 361, Sept. Term 2025 (Appellate Court of Maryland, reported, 29 Oct 2025)

Appellate Court of Maryland · Maryland

last revised 2025-10-29last verified 2026-09-041 versioncountry page →

Judgment (guidance)In forceVerification dutySupervision

map categories:Sanctions for AI misuseDuty to verify AI outputSupervision of AI workDisclosure of AI use in filings

Maryland's leading AI-hallucination decision. The Appellate Court of Maryland published Mezu as a warning to the bar, holding that failing to read AI-generated citations before filing can produce briefs citing multiple fictitious cases, and referred the signing attorney to the Attorney Grievance Commission. Delegation to a law clerk was no defence.

Applies to
lawyers, firms
Effective
See version history
Current version
Reported opinion · 29 Oct 2025
Last verified
04 Sept 2026
Official text
www.mdcourts.gov/data/opinions/cosa/2025/0361s25.pdf

What the document requires

  • The court reported the case to address the recurring problem of AI-drafted briefs containing incorrect, inaccurate or fictitious citations
  • The brief contained citations to multiple fictitious cases, misquoted passages, and citations that did not support the propositions cited
  • Failure to read AI-generated citations before filing is the operative breach
  • Based on the nature and severity of the conduct the court referred the attorney to the Attorney Grievance Commission
  • Delegation of research to a law clerk did not excuse the signing attorney

Version history

VersionDateWhat changedSource
Reported opinioncurrent2025-10-29Reported opinion issuedofficial

Related court incidents on the record

Sources

Cite this record

SafeLegalAI Legal AI Regulation Tracker, "Mezu v. Mezu, No. 361, Sept. Term 2025 (Appellate Court of Maryland, reported, 29 Oct 2025)" (Appellate Court of Maryland, Reported opinion, 2025-10-29), safelegalai.com/regulation/us-state/us-md-mezu-v-mezu (accessed 2026-09-04). Data: CC BY 4.0.

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