Taylor v. Prince George's County, Maryland

What sanction did the court impose?

The magistrate judge made no recommendation on the citation errors, bringing them to the presiding district judge's attention "so that the presiding judge can take whatever action she believes to be necessary and appropriate." No sanction, order to show cause, or disciplinary referral was imposed in the Report and Recommendation itself. On the underlying motion, the magistrate judge recommended that the defendants' petition for attorney's fees be denied.

Why does Taylor v. Prince George's County, Maryland matter for law firms using AI?

Taylor v. Prince George’s County is a December 16, 2025 Report and Recommendation from Chief U.S. Magistrate Judge Timothy J. Sullivan in a wrongful-death and survival action arising from a fatal car crash during a police pursuit. The matter reached the magistrate judge on the defendants’ petition for attorney’s fees after they prevailed on summary judgment and on appeal; the magistrate judge recommended that the fee petition be denied. The AI-adjacent issue is secondary: in a standalone section, the magistrate judge catalogued several defective citations in the plaintiffs’ response brief, including a miscited Arnold v. Burger King Corp., a reporter-citation mixup, and a fabricated quotation attributed to EEOC v. Great Steaks, Inc. The magistrate judge noted these are “the types of errors that generative artificial intelligence tools make when hallucinating case citations” but expressly declined to find that AI caused them, and made no sanctions recommendation, leaving any action to the presiding district judge. For managing partners, the signal is that even where a court cannot confirm AI use, defective citations now draw a court’s attention as a possible AI-hallucination pattern.