Future Field Solutions, LLC v. Van Norstrand
U.S. District Court, District of Maryland · D. Md. · Maryland bar guidance
Verified May 14, 2026
- Citation
- Future Field Solutions, LLC v. Van Norstrand, No. DKC 23-1301, 2026 WL 183522 (D. Md. Jan. 23, 2026) (Chasanow, J.)
- Decided
- January 23, 2026
Summary
Counterclaim Defendants moved for an order to show cause why Erik Van Norstrand and his counsel C. Edward Hartman III should not be sanctioned for allegedly using artificial intelligence to draft a summary judgment reply brief that contained incorrect case citations, unusual grammatical errors, responses to arguments the opposing party never made, and false factual assertions. Judge Deborah K. Chasanow catalogued eleven specific examples of false or fabricated assertions in the reply, including references to "proposed findings" that did not exist, a nonexistent "tried-by-consent record," and characterizations of arguments (economic loss doctrine, statute of limitations, integration/anti-reliance) that opposing counsel had never raised.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No sanctions imposed at this time. The court denied the show-cause request without prejudice, noting it had already granted much of the relief sought by declining to consider the improperly asserted arguments and assertions of fact, but stated "[t]he matter may be revisited later, if appropriate." The court reaffirmed that AI use in drafting briefs is not itself prohibited, but Rule 11(b) requires counsel to conduct a reasonable inquiry into the legal arguments and factual assertions made in any filing.
Why does Future Field Solutions, LLC v. Van Norstrand matter for law firms using AI?
Future Field Solutions illustrates how a court can address suspected AI-generated filings without ever formally finding that AI was used. Judge Chasanow declined to issue a show-cause order and instead documented eleven specific false or fabricated assertions in the reply brief, treating them through the ordinary mechanism of refusing to consider unsupported arguments. For a managing partner, the lesson is that the reputational and procedural cost of filing a brief riddled with rebuttals to arguments the other side never made arrives well before any formal sanctions ruling, and the court explicitly reserved the right to revisit sanctions later in the litigation.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.