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AII-1001-46619
ConfirmedA court, a regulator or the organization itself has stated the core facts, or the record cites a court or regulator source.

Maryland lawyer sanctioned for submitting AI-generated fake legal citations

A Maryland family law attorney was sanctioned for filing court documents containing fabricated legal citations generated by ChatGPT. Judge Kathryn Grill Graeff found that neither the attorney nor his law clerk had verified the false cases, and ordered both to complete ethical AI training and establish citation verification protocols.

9 November 2025 Β· Adam Hyman Β· Reliability and hallucination
9 November 2025
AII-1001-466192 sources ↓
Quick facts
Category
Reliability and hallucination
Country
United States
Source
Futurism
Date
9 November 2025
Drafted by
Raidu Incident Detection

What happened

Attorney Adam Hyman filed a complaint for divorce in Maryland appellate court containing legal citations generated by ChatGPT. Many citations referenced case law that did not exist, and some existing citations contradicted arguments in the brief.

Hyman stated he was not directly involved in the research and blamed a law clerk who used ChatGPT to find citations and edit the brief. The clerk was unaware of the risks of AI hallucinations.

Reported impact

Judge Kathryn Grill Graeff noted that the improper citations did not satisfy the requirement of competent representation in the case.

Index analysis

Judge Graeff wrote that 'it is unquestionably improper for an attorney to submit a brief with fake cases generated by AI' and that 'a competent attorney reads the legal authority cited in court pleadings to make sure that they stand for the proposition for which they are cited.'

Governance controls

Hyman was required to admit responsibility for the improper case citations. Both Hyman and the law clerk were required to complete legal education courses on the ethical use of AI and implement office-wide protocols for citation verification.

Judge Graeff issued the opinion specifically to address a problem recurring in courts around the country regarding AI use in the courtroom.

Classification

Category
Reliability and hallucination
Industry
Government, security and defence
Country
United States
Harm status
Actual harm
Intent
Unintentional
Timing
Post-deployment
Harm types
Reputational, Public interest
Failure modes
Hallucination, Fabricated citation, Overreliance
AI systems
ChatGPT

Sources and evidence

This record was researched and written by the Index, based on the following original reporting.

Futurism
Judge Blasts Lawyer Caught Using ChatGPT in Divorce Court, Orders Him to Take Remedial Law Classes
9 November 2025
The Baltimore Sun
Citing 'hallucinated' AI cases gets Harford divorce lawyer in trouble with Maryland Appellate Court
10 November 2025