District of Maryland “Hallucination” Decision

Aziz v. U.S., 2026 WL 1132884 (D. Md. Apr. 27, 2026)(Abelson, J.), is of note only because it is in the District of Maryland, where I practice.

Plaintiffs “filed an unusually high number of motions in a short amount of time.”

The latest flurry worsens a pattern of repeated filings: the Court’s previous order denied four of Plaintiffs’ motions that were filed within the space of a few weeks…. The likeliest explanation is that Plaintiffs are using an artificial intelligence (AI) tool. This inference is further corroborated by numerous hallucinated cases and citations: for example, in ECF No. 59 at 8, Plaintiffs’ quote a previous case of this Court (“United States v. $17,900 in U.S. Currency”) that does not appear to exist.

The Court added:

Although the use of AI tools for legal research or drafting is not inherently improper, Plaintiffs’ avalanche of filings here, whether AI-generated or not, have burdened the Court, advanced frivolous arguments, misstated the record, and fabricated legal authorities. Parties bear responsibility for the filings they sign, regardless of actual authorship. See LBCMT 2007-C3 Urbana Pike, LLC v. Sheppard, 302 F.R.D. 385, 388 (D. Md. 2014) (“[P]ro se litigants[,] where appropriate, are still held to a basic standard of accountability for the contents of their court papers.”). This responsibility includes the duty to include accurate factual and legal citations. See United States v. Malik, Case No. 16-cr-324-JKB, 2025 WL 2687413, at *1 n.2 (D. Md. Sept. 19, 2025) (“While the Court affords pro se litigants substantial latitude in their filings, that does not provide permission to include nonexistent quotations and citations. In particular, when using generative artificial intelligence, litigants must be aware ‘that such platforms sometimes ‘hallucinate,’ meaning they provide inaccurate responses.’ ”) (quoting Kruglyak v. Home Depot U.S.A., Inc., 774 F. Supp. 3d 767, 770 (W.D. Va. 202)).

The Court, in order “to facilitate an efficient and fair resolution of this case, … will limit the length of any new motions or oppositions to four pages (this limitation will apply to both sides).”  Specific filings by the Attorney General of Maryland and the United States were exempted.

The decision ends with a warning: “If Plaintiffs continue to file frivolous motions or include fabricated citations, and/or violate the page limitation set forth in the accompanying order, the Court may enjoin them from submitting further filings or consider imposing other sanctions.”

A non-exhaustive list of other recent examples in this District follows:

“In this discrete instance, the court will not issue a Rule 11 show cause order as to Plaintiff’s citation to a hallucinated case. Nevertheless, Plaintiff is strongly cautioned: should he engage in similar conduct in the future (i.e., citation to hallucinated authorities or the like), the court may exercise its discretion to issue an order to show cause why he should not face sanctions under Rule 11.”  Johnson v. Nationstar Mortgage, LLC, et al., 2026 WL 1179961, at *5 (D. Md. Apr. 30, 2026).

“It is unclear whether Plaintiffs’ errors are the result of their attorneys relying upon (and failing to verify) arguments and citations generated by AI or some other circumstances. Courts have sanctioned parties and disciplined attorneys for relying upon hallucinated, AI-generated case citations. See, e.g., Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341, 342 (E.D.N.Y. 2025) (collecting cases); United States v. Hayes, 763 F. Supp. 3d 1054, 1071 (E.D. Cal. 2025) (same). I make no recommendation regarding these errors but bring them to the Court’s attention so that the presiding judge can take whatever action she believes to be necessary and appropriate.” Taylor v. Prince George’s Cnty., Maryland, 2025 WL 3640370, at *5 (D. Md. Dec. 16, 2025).

“Given that counsel has obviously undertaken serious efforts to correct the error and is sufficiently remorseful for the improper use of generative AI, the Court finds that no additional action is warranted. However, Plaintiffs’ counsel is warned that future filings containing erroneous citations of the type exemplified here may ultimately lead to the issuance of sanctions under Rule 11.”  Neal v. Frayer, 2025 WL 3204710, at *15 (D. Md. Nov. 17, 2025).

See generally:

• Hallucinations Are “Old News,” But a Recent Maryland Decision Addresses Ethical Contours
• Maryland Fake Citation Case – Court Issues a Warning – Referral to Atty. Grievance Comm’n.
• Maryland’s Proposed Anti-Hallucination Rule
• Fourth Circuit Technology Agnostic Hallucination Decision Results in Admonishment
• “Hallucinations” by West’s CoCounsel?
• “Hallucinations” by West and Lexis AI?  A Cautionary Study and Cautions About the Study
• Child’s Best Interest Standard Trumps Hallucination Sanction
• Court Suggests That Opposing Counsel Also Failed to Check Citations

UPDATE: Dan Belson, AI hallucinations lead judges to scold Severna Park Lawyers(Daily Record May 19, 2026)(“Two partners at a Severna Park law firm were scolded by a federal Maryland judge after they filed briefs containing fake case law quotes generated by an artificial intelligence tool, only a few months after threats of sanctions for similar errors in Washington, D.C.”).