Mbow v. Mackert
U.S. District Court, District of Maryland · D. Md. · Maryland bar guidance
Verified October 1, 2026
- Citation
- Mbow v. Mackert, No. 24-cv-3674-BAH, ECF No. 41 (D. Md. July 17, 2026); see also 2026 WL 221711 (D. Md. Jan. 28, 2026)
- Decided
- July 17, 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 did the court warn about?
No sanction was imposed. In a January 28, 2026 opinion, Judge Hurson ordered Plaintiff's counsel to respond within twenty-one days to the fabricated and misquoted citations it chronicled, and counsel withdrew those citations (ECF No. 33). In a July 17, 2026 opinion on Baltimore County's motion to dismiss, the court noted that counsel had again cited a non-existent case she had previously acknowledged as fake, said it would not address the issue further at that time, and added that "the Court has had enough of Plaintiff's fake citations and does not expect to see them again" (ECF No. 41, p. 5 n.4).
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
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.
- 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.