Maryland’s Proposed Anti-Hallucination Rule

Maryland’s Standing Committee on Rules of Practice and Procedure will hold an open meeting on March 20, 2026. In part, the agenda includes a proposed artificial intelligence rule.

Md. Rule 1-311 is the analog of Fed.R.Civ.P.26(g). As currently drafted, Rule 1-311 states that the signature of an attorney on a pleading or paper constitutes a certification that the attorney has read it.  The proposed amendment will add that the attorney has confirmed the existence and authenticity of each cited legal authority:

The signature of an attorney on a pleading or paper constitutes a certification that the attorney has read the pleading or paper and has confirmed the existence and authenticity of each legal authority cited; that to the best of the attorney’s knowledge, information, and belief there is good ground to support it the pleading or paper; and that it the pleading or paper is not interposed for improper purpose or delay.

Willful violations can result in attorney disciplinary action.

The Reporter’s Note cites to Mezu v. Mezu, 267 Md. App. 354 (2025). That, and other, Maryland hallucination cases were described in:

• 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)

See generally, Child’s Best Interest Trumps Sanction for Possibly Hallucinated Case Citation (Mar. 15, 2026); Fourth Circuit Technology Agnostic Hallucination Decision Results in Admonishment (Mar. 13, 2026) Litigant Forfeited Claim that Court Erred by Relying on Hallucinated/Fictional Cases (Mar. 11, 2026).

The Reporter’s Note states that the recommended amendment will “make explicit what already is implicit in the Rule: an attorney has the obligation to confirm the existence and authenticity of any cases cited in a filing.”