Maryland Copy and Paste “Hallucinations” Case

An attorney who copied and pasted non-existent case law from a pro se memorandum was sanctioned.

“Father cites three cases that do not exist as cited….”  Additionally, actual cases were cited for propositions that did not exist in the real case. One was “overstated.” Ajakaiye v. Oladipupo, 2026 WL 1733336 (Appl. Ct. Md. Jun. 16, 2026)(unreported)(custody and visitation).[1]

The Court wrote that: “Given that these irregularities are littered throughout Father’s briefing, the Court was concerned that Father’s counsel had utilized artificial intelligence (AI) in drafting the briefs.”  It issued a show cause order.

The Court explained that: “Father’s counsel filed the Response to Show Cause Order (the ‘Response’), generally stating that he does not use artificial intelligence in drafting of any of his briefs, but conceding that he ‘drew from’ Father’s pro se trial memoranda in preparing Father’s briefs.”  Id. at n. 13 (cleaned up). The Court wrote:

Assuming the truth of everything Father’s counsel represents in the Response, the fact remains that counsel, throughout his briefing, used quotations that do not exist and cited caselaw that does not support the stated propositions. The Court’s review of Father’s briefing confirms that, for most of the offending citations, Father’s counsel simply copied and pasted from the Father’s pro se second motion for reconsideration. Father’s counsel further concedes that he did not confirm whether AI was used in the Father’s preparation of that second motion for reconsideration, seemingly relying on the fact that the pro se briefing was drafted with the assistance of Father’s sister, who is a non-practicing attorney (having attended a foreign law school).

The Court recently discussed the pitfalls of relying on AI in filings and how such conduct can implicate various provisions of the Maryland Attorneys’ Rules of Professional Conduct. See Mezu v. Mezu, 267 Md. App. 354, 368-74 (2025). Because we recently spoke on this issue, we will not belabor the point here. But we write separately to add that it is no less problematic for an attorney to blindly copy-and-paste from other filings generated using AI—which is likely what happened here—than it is to use AI improperly in the first instance. As we did in Mezu, we will refer this matter to the Attorney Grievance Commission. [emphasis added].

For more Maryland authority, see:

• Maryland Fake Citation Case – Court Issues a Warning – Referral to Atty. Grievance Comm’n. (Nov. 2, 2025);
• Hallucinations Are “Old News,” But a Recent Maryland Decision Addresses Ethical Contours  (Jan. 17, 2026);
• Maryland’s Proposed Anti-Hallucination Rule (Mar. 16, 2026).

[1] “This is an unreported opinion. This opinion may not be cited as precedent within the rule of stare decisis. It may be cited for its persuasive value only if the citation conforms to Rule 1-104(a)(2)(B).”