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Maryland Appellate Court Refers Bel Air Lawyer Over AI-Fabricated Citations

The opinion frames the lapse as a failure of competent representation, signaling tougher oversight of AI-assisted legal research.

Overview

  • The court said Hyman’s divorce-appeal brief contained 11 faulty citations—four nonexistent, five unsupported, and two miscitations.
  • Judges concluded he failed to provide competent representation because he did not read the cited authorities and remains responsible for his clerk’s work.
  • Judge Kathryn Grill Graeff referred him on Oct. 29 to the Maryland Attorney Grievance Commission, with no further discipline reported so far.
  • The opinion warns some generative models hallucinate legal authorities roughly 30–50% of the time, marking the appellate court’s first direct treatment of the problem.
  • The case aligns with a broader rise in sanctions over AI citation errors, including a May incident involving attorney Matthew Reeves, as experts urge stronger verification and court-backed citation safeguards.