Boyd v. Lee
Appellate Court of Maryland · Md. Ct. Spec. App. · Maryland bar guidance
Verified May 1, 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
What sanction did the court impose?
Appeal dismissed under Maryland Rule 8-602(c)(5); costs assessed to appellant. The court issued an order to show cause on potential sanctions and referral to the Maryland Attorney Grievance Commission for citing hallucinated and unsubstantiated case law, citing Mezu v. Mezu, 267 Md. App. 354 (2025). No monetary sanction was imposed in this opinion; the show-cause and referral question remained open as of the filing date.
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 referring offending counsel to the Attorney Grievance Commission on its own initiative.