FOR YOUR PRACTICE | UPDATES FROM THE JUDICIARY
U.S. District Court for Maryland Addresses Hallucinated Cases BY PAMELA LANGHAM, ESQ.
RECENT RULINGS FROM the U.S. District Court for the District
Hallucinated cases are “inaccurate depictions of information from AI models that suffer from incomplete, biased, or otherwise flawed training data.”
of Maryland have spotlighted a serious concern in legal practice: the submission of court filings permeated with fabricated or “hallucinated” cases and citations, generated by generative artificial intelligence (AI). In two separate matters, although involving the same lawyer, the court confronted legal pleadings in which counsel relied on non-existent authorities cited in the court filings, raising serious questions about diligence, ethics, and the integration of AI technologies into legal research and drafting. These incidents underscore the reality that lawyers continue to rely on AI technology without independently verifying its output. Lawyers and legal teams navigating AI technology should take note.
Hallucinated cases are “inaccurate depictions of information from AI models that suffer from incomplete, biased, or otherwise flawed training data.”1 These “hallucinations” are a travesty in the legal profession. They mislead the court and opposing counsel, waste judicial resources, and undermine the credibility of the legal profession. Across the nation, 1
Mezu v. Mezu No. 361, Sept. Term 2025, 2025 WL 3022460, at *3 (Md. App. Oct. 29, 2025).
MARYLAND BAR JOURNAL | VOLUME 7 ISSUE 3
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