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