Boyd v. Lee
Appellate Court of Maryland · Md. Ct. Spec. App. · Maryland bar guidance
Verified September 30, 2026
- Citation
- Boyd v. Lee, No. 1685, Sept. Term 2024, 2026 WL 111263 (Md. Ct. Spec. App. Jan. 14, 2026) (unreported)
- Decided
- January 14, 2026
Summary
Appellant Mataw Boyd's counsel, Michael A. Troy, filed an appellate brief in a divorce appeal that contained at least eight citation irregularities out of fourteen cases cited: four cases (Lohrmann v. Lohrmann, Townsend v. Meyer, Bowie v. Bowie, Furr v. Furr) did not exist, and four others (including Md. State Bd. of Elections v. Libertarian Party of Md., Davis v. Davis, Lee v. Andochick, and Pickett v. Noba) did not support the propositions for which they were cited. Judges Nazarian, Zic, and Kenney noted the AI-hallucination pattern and, on December 2, 2025, ordered Mr. Troy to show cause why he should not be sanctioned and referred to the Attorney Grievance Commission. Mr. Troy also repeatedly failed to file the eight paper copies of the brief required by Maryland Rules 20-404(b) and 20-406(a)(2)(B).
- AI tool:
- Unspecified generative AI
How did the court address the AI-related conduct?
Appeal dismissed under Maryland Rule 8-602(c)(5); costs assessed to appellant. On December 2, 2025 the court had ordered Mr. Troy to show cause why he should not be sanctioned and referred to the Maryland Attorney Grievance Commission for citing hallucinated and unsubstantiated case law, citing Mezu v. Mezu, 267 Md. App. 354 (2025). The opinion calls the AI issue "not dispositive here" and imposes no sanction and makes no referral. The case is closed (mandate issued February 6, 2026). Whether the court separately ruled on the show-cause orders is not established from the public docket.
Why does Boyd v. Lee matter for law firms using AI?
Boyd is the second Maryland Appellate Court opinion in under a year (after Mezu v. Mezu) to flag fabricated and misrepresented citations in a counsel-signed brief, and it shows the court treating Rule 1-311(b) certification as the operative hook for discipline rather than waiting on a Rule 11 analog. For managing partners, the practical signal is that Maryland’s intermediate appellate court is now actively auditing tables of authorities and, on its own initiative, ordering counsel to show cause why they should not be referred to the Attorney Grievance Commission.
Sources
Primary sources
- https://www.courts.state.md.us/sites/default/files/unreported-opinions/1685s24.pdf
- https://www.courts.state.md.us/appellate/unreportedopinions/list/202601
- Whether the court ruled on the December 2, 2025 show-cause orders is not established. The public docket lists entry titles only; the one order entered after counsel's December 10, 2025 answer and before the opinion is a December 12, 2025 entry titled 'Order' whose text is not public. The opinion says the court struck counsel's first response for lacking a certificate of service, which may be that order. The December 12 order is on the manual pull list.