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Abybatou Mbow v. Officer Michael Mackert et al. (1)

Court
D. Maryland
Jurisdiction
USA
Decided
2026-01-28
AI tool
Implied
Outcome
Order to Show Cause
Monetary penalty
None reported

What was hallucinated

Misrepresented: Case Law | Counsel cited "Eichholz v. Camp, 36 F.4th 908, 917 (4th Cir. 2022)"; Court noted the reporter information more closely matches an unrelated Ninth Circuit opinion and the citation is inaccurate. || Misrepresented: Case Law | Counsel cited Holloway v. State, 232 Md. App. 272, 290 (2017) with a pinpoint page that does not exist (opinion ends at p.285) and relied on it for an unrelated proposition; Court noted the page and proposition are incorrect. || Fabricated: Case Law | Counsel cited a non-existent decision as "Bush v. Lucas, 598 F. Supp. 3d 303, 316 (D. Md. 2022)"; Court found no such case at that citation and noted the closest match is a different 5th Circuit opinion. || False Quotes: Case Law | Counsel quoted language attributed to Okwa v. Harper that does not appear in that opinion; Court observed the quoted language is absent from Okwa. || Misrepresented: Case Law | Counsel mis-summarized or misquoted multiple Fourth Circuit cases (e.g., misquoting Colleton Preparatory Acad. and United States v. Moradi); Court flagged these misquotes in its opinion. || False Quotes: Case Law | Counsel cited Haines v. Vogel as supporting that non-consensual sexualized photography during arrest is "outrageous," but Court found Haines did not involve an arrest or sexualized photography and dismissed the asserted support. || Misrepresented: Case Law | Counsel cited "Md. Comm'n on Hum. Rels. v. Balt. Cty., 439 A.2d 1121 (Md. 1982)" for a proposition; Court identified the reporter information corresponds to Fields v. State, 439 A.2d 1121 (1982), not the named case.

Sanction teardown · D. Maryland, USA · 2026-01-28

Abybatou Mbow v. Officer Michael Mackert et al. (1)

What happened

In D. Maryland, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Misrepresented (Case Law)
    Counsel cited "Eichholz v. Camp, 36 F.4th 908, 917 (4th Cir. 2022)"; Court noted the reporter information more closely matches an unrelated Ninth Circuit opinion and the citation is inaccurate.
  • Misrepresented (Case Law)
    Counsel cited Holloway v. State, 232 Md. App. 272, 290 (2017) with a pinpoint page that does not exist (opinion ends at p.285) and relied on it for an unrelated proposition; Court noted the page and proposition are incorrect.
  • Fabricated (Case Law)
    Counsel cited a non-existent decision as "Bush v. Lucas, 598 F. Supp. 3d 303, 316 (D. Md. 2022)"; Court found no such case at that citation and noted the closest match is a different 5th Circuit opinion.
  • False Quotes (Case Law)
    Counsel quoted language attributed to Okwa v. Harper that does not appear in that opinion; Court observed the quoted language is absent from Okwa.
  • Misrepresented (Case Law)
    Counsel mis-summarized or misquoted multiple Fourth Circuit cases (e.g., misquoting Colleton Preparatory Acad. and United States v. Moradi); Court flagged these misquotes in its opinion.
  • False Quotes (Case Law)
    Counsel cited Haines v. Vogel as supporting that non-consensual sexualized photography during arrest is "outrageous," but Court found Haines did not involve an arrest or sexualized photography and dismissed the asserted support.
  • Misrepresented (Case Law)
    Counsel cited "Md. Comm'n on Hum. Rels. v. Balt. Cty., 439 A.2d 1121 (Md. 1982)" for a proposition; Court identified the reporter information corresponds to Fields v. State, 439 A.2d 1121 (1982), not the named case.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Order to Show Cause

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/1420/Mbow_v._Mackert_USA_28_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1420/Mbow_v._Mackert_USA_28_January_2026.pdf

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