| Court - Judge Name |
Effective Date |
Applicable To | Categories |
Summary |
| Md. App. Ct. – Judge Kathryn Grill Graeff | 10/29/2025 | Generative AI | Generative AI Usage | In Mezu v. Mezu, 2025 Md. App. LEXIS 898 (Md. Oct. 29, 2025), the appellee-mother included hallucinated citations and incorrect case propositions in her brief on appeal from the circuit court’s order modifying the marital settlement agreement. In response to the court’s order to show cause as to why the appellee-mother’s attorney should not be sanctioned, the attorney told the court that he had little involvement in his law clerk’s research for this case and that “his oversight was insufficient.” Relatedly, the attorney told the court that “he typically did not read the cases he cited in pleadings submitted to the court.” The law clerk separately informed the court that she used ChatGPT and VLex for legal research and that her review of the GenAI-generated cases “did not raise any ‘red flags.’” Even after the supervising attorney made edits to the draft brief, the law clerk then relied on ChatGPT to perform a cite check for accuracy. Until the court issued its order to show cause, the law clerk was unaware of hallucinations and was under the impression that the GenAI tools were “data or information aggregator[s] that allowed for more in-depth and extensive research results.” The court found the attorney to be in violation of various provisions of the Maryland Attorney’s Rules of Professional Conduct regarding asserting meritorious claims, competent representation, and attorney supervision. As there was no request for monetary penalties, Judge Graeff referred the case to the Attorney Grievance Commission given the “nature and severity of the conduct.”
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| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| D. Md. – Judge James K. Bredar | 9/27/2025 | Generative AI | Generative AI Usage | In United States v. Malik, 2025 WL 2687413 (D. Md. Sept. 27, 2025), the pro se plaintiff included inaccurate or nonexistent citations in his motion for early termination of supervised release. The court noted that the plaintiff’s citation to provisions of the U.S. Sentencing Guidelines and provisions of the state administrative code were “not accurate” and that the citations “either do not exist or do not contain the information that he attributes to them.” In addressing the inaccurate citations, Judge Bredar cautioned that the latitude given to pro se litigants does not include “permission to include nonexistent quotations and citations” and warned litigants that GenAI platforms “sometimes ‘hallucinate.’” The court advised the pro se plaintiff to “take care that his filings with the Court do not contain any such ‘hallucinations’” and denied his motion on other grounds. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting |
Maryland
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