Incident Tracker / United States (state)
Mezu v. Mezu (Md. App. Ct. 2025), No. 361 Sept. Term 2025
·Appellate Court of Maryland·US-STATERegulatory referral
Maryland's intermediate appellate court referred an attorney to the state Attorney Grievance Commission after his client's brief cited multiple fictitious ChatGPT-generated cases and he conceded he routinely did not read the authorities he cited — a bar-discipline referral rather than a monetary sanction.
- Court
- Appellate Court of Maryland
- Date
- 2025-10-29
- Who used the AI
- Not recorded
- AI tool
- ChatGPT
- Conduct
- The mother's appellate brief cited multiple fictitious AI-generated cases and cases not supporting the propositions cited. At oral argument, counsel admitted he typically did not read the cases he cited.
- Outcome
- Regulatory referral
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- Maryland Attorney Grievance Commission: The court referred the attorney to the Maryland Attorney Grievance Commission based on the nature and severity of the conduct. (2025-10-29)
- Status
- Verified against listed sources
- Last checked
- 2026-09-16
What was fabricated or misused
- multiple fictitious cases cited in Mother’s brief — the court did not list their names
- misquoted passages and citations to cases that did not support the propositions cited — the court did not list them
What the court said
“Mother’s brief in this case is replete with citation irregularities. These irregularities include citations to multiple fictitious cases, as well as misquoted passages and citations to cases that do not support the proposition for which they are cited.”
“The law clerk utilized AI in her research, explaining that she began by using ChatGPT to search for relevant cases.”
“Implicit in the requirement that an attorney certify that there is good ground to support the contentions raised is that the attorney has read the primary cases on which the attorney relies for the argument submitted.”
“Based on all the circumstances, we shall refer this case to the Attorney Grievance Commission.”
Timeline
- Circuit Court modified the marital settlement agreement and incorporated it into its order.
- Father noted an appeal from the March 19 order.
- Appellate Court filed its reported opinion and referred counsel to the Attorney Grievance Commission.
Why this case matters
Mezu gives a reported Maryland appellate statement on AI citations and lawyer supervision. Unlike Mata v Avianca, it did not impose money; the sanction path was a referral to the Attorney Grievance Commission. The opinion links three duties: the signing lawyer must read the primary cases, must supervise a law clerk's research, and cannot treat internet summaries or AI answers as a substitute for verification. It is also a state-family-law record, not a federal civil motion, so it shows the same problem reaching ordinary domestic appeals.
Practice note
Before filing an appellate brief, the lawyer who signs it should open every cited case, confirm the citation, and read the cited passage. A clerk may help collect authorities, but the lawyer must ask how the research was done and verify it personally. If AI or an AI-linked search tool was used, check the result in an official reporter or legal database before filing.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Mezu v. Mezu (Md. App. Ct. 2025), No. 361 Sept. Term 2025”, safelegalai.com/tracker/mezu-v-mezu (accessed 2026-09-16). Data: CC BY 4.0.