Mbow v. Mackert
U.S. District Court, District of Maryland · D. Md. · Maryland bar guidance
Verified April 26, 2026
- Citation
- Mbow v. Mackert, No. 24-cv-3674-BAH, 2026 WL 221711 (D. Md. Jan. 28, 2026)
- Decided
- January 28, 2026
Summary
Plaintiff's counsel Latoya A. Francis-Williams filed responses to motions containing numerous case citations that, in Judge Brendan A. Hurson's estimation, "perhaps as many as half" appeared "to be inaccurate or non-existent." Among the defective citations was "Bush v. Lucas, 598 F. Supp. 3d 303, 316 (D. Md. 2022)," cited for a state-law racial discrimination proposition. The court could not locate a case at that citation. Other filings misquoted Fourth Circuit precedent (Colleton Preparatory, Moradi, Consolidated Masonry), cited a non-existent page of Holloway v. State, and attributed quoted language to Okwa v. Harper and Haines v. Vogel that does not appear in either opinion.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause: Judge Hurson ordered Plaintiff's counsel to respond within twenty-one (21) days to the allegations of fabricated and misquoted citations chronicled in the opinion and in Baltimore County's reply brief. No monetary sanction imposed at this stage. Court noted pattern of similar sua sponte show-cause orders within the Fourth Circuit.
Why does Mbow v. Mackert matter for law firms using AI?
Mbow illustrates the pattern courts increasingly recognize: not just one fake citation, but a filing salted with citations that resolve to real reporter slots occupied by unrelated cases, page numbers that exceed the cited opinion’s length, and quoted language that appears nowhere in the cited source. For a managing partner, the diligence question is not whether counsel ran a citation through Westlaw at all, but whether the firm requires verification of the proposition each cited case actually stands for before a brief leaves the office.
Sources
Further reading
- CourtListener docket search (aggregator)
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
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.
- Specific use of generative AI is not named in the order; the AI tool is inferred from the pattern of fabricated citations and misattributed quotations characteristic of LLM hallucinations.