Maryland — AI Regulations

28 JAN 2026 · Court Case

Abybatou Mbow v. Officer Michael Mackert et al.

Fabricated: Case Law | Counsel cited a non-existent decision as "Bush v. Lucas, 598 F. Supp. 3d 303, 316 (D. Md. 2022)"; Court found no such case at that citation and noted the closest match is a different 5th Circuit opinion. || False Quotes: Case Law | Counsel quoted language attributed to Okwa v. Harper that does not appear in that opinion; Court observed the quoted language is absent from Okwa. || False Quotes: Case Law | Counsel cited Haines v. Vogel as supporting that non-consensual sexualized photography during arrest is "outrageous," but Court found Haines did not involve an arrest or sexualized photography and dismissed the asserted support. || Misrepresented: Case Law | Counsel cited "Md. Comm'n on Hum. Rels. v. Balt. Cty., 439 A.2d 1121 (Md. 1982)" for a proposition; Court identified the reporter information corresponds to Fields v. State, 439 A.2d 1121 (1982), not the named case. || Misrepresented: Case Law | Counsel cited "Eichholz v. Camp, 36 F.4th 908, 917 (4th Cir. 2022)"; Court noted the reporter information more closely matches an unrelated Ninth Circuit opinion and the citation is inaccurate. || Misrepresented: Case Law | Counsel cited Holloway v. State, 232 Md. App. 272, 290 (2017) with a pinpoint page that does not exist (opinion ends at p.285) and relied on it for an unrelated proposition; Court noted the page and proposition are incorrect. || Misrepresented: Case Law | Counsel mis-summarized or misquoted multiple Fourth Circuit cases (e.g., misquoting Colleton Preparatory Acad. and United States v. Moradi); Court flagged these misquotes in its opinion.

Court: D. MarylandParty: Lawyer

Harms: Hallucination in legal filings

23 JAN 2026 · Court Case

Future Field Solutions, LLC v. Van Norstrand

Misrepresented: Exhibits & Submissions | Reply mischaracterized the pleadings by stating 'Count III of the Counterclaim principally seeks...equitable relief,' while the court observed Count III principally sought compensatory damages. || Fabricated: Case Law | Reply contained incorrect or unspecified case citations and atypical errors suggesting non-vetted, AI-like drafting; court noted incorrect citations and unusual grammatical errors as part of the concern. || Misrepresented: Exhibits & Submissions | Reply brief asserted that Defendants argued 'where there is no merger paper, there is no successor liability,' which the court found Defendants made no such argument. || Misrepresented: Exhibits & Submissions | Reply brief claimed Defendants contended successor-liability doctrines do not apply to LLCs; court found no such argument in the record. || Misrepresented: Exhibits & Submissions | Reply falsely asserted that Defendants migrated Van Norstrand's personal Google content into Office 365 and produced it, but the court records show Van Norstrand himself testified he migrated the content. || Fabricated: Exhibits & Submissions | Reply contained materially incorrect factual timeline claims (e.g., alleging insider spouse-loans, PeriArchon purchase, Lockheed contract diversion, and lockouts occurred before dates supported by the record); court listed these as false assertions.

Court: D. MarylandParty: Lawyer

Harms: Hallucination in legal filings

23 JAN 2026 · Court Case

Future Field Solutions v. Nordstrand

Misrepresented: Exhibits & Submissions | Reply contained inaccurate timeline/factual assertions about when alleged actions occurred (court identified timing errors). || Misrepresented: Exhibits & Submissions | Reply claimed Counterclaim Defendants argued a point they did not (false characterization of opposing brief). || Misrepresented: Exhibits & Submissions | Reply falsely stated that Counterclaim Defendants migrated Van Norstrand's personal Google content into Office 365 and produced it; court found that Van Norstrand himself migrated the content. || Fabricated: Case Law | Reply included incorrect or erroneous case citations and other legal citations and grammatical errors flagged by opposing party and the court. || Misrepresented: Exhibits & Submissions | Reply attributed an argument to Counterclaim Defendants that they never made (false characterization).

Court: D. MarylandParty: Lawyer

Harms: Hallucination in legal filings

16 JAN 2026 · Court Case

Tafah et al. v. Lake Village Townhomes et al.

Misrepresented: Case Law | Plaintiffs cited 'White v. Olathe Housing Auth., 1997 U.S. Dist. LEXIS 6029 (D. Kan. 1997)', but the court noted the reporter entry corresponds to Shakman v. Democratic Org., 1997 U.S. Dist. LEXIS 6029 (N.D. Ill. 1997), reflecting an inaccurate/misplaced citation. || Fabricated: Case Law | Plaintiffs cited 'Bourne v. Gatliff Building Co., 380 F.3d 848 (5th Cir. 2004)', a citation the court found does not appear to exist and noted the closest match is Matchett v. Dretke, 380 F.3d 844 (5th Cir. 2004). || Misrepresented: Case Law | Plaintiffs cited 'Corey v. Secretary of Housing & Urban Dev., 719 F.2d 122 (5th Cir. 1983)', but the court identified the correct reporter/volume corresponds to Baber v. Edman, 719 F.2d 122 (5th Cir. 1983), indicating a misattributed case name.

Court: D. MarylandParty: Pro Se Litigant

Harms: Hallucination in legal filings

01 JAN 2026 · Law / Act

2026 Chatbot Legislation — Maryland HB 952 [URL: https://mgaleg.maryland.gov/mgawebsite/Legislation/Details/hb0952?ys=2026rs]

2026 chatbot legislation — Passed Chamber

Generative AI ·Data Privacy & Protectionmgaleg.maryland.gov ↗

16 DEC 2025 · Court Case

PRM Group, Inc. v. Paralegal Bootcamp LLC

Fabricated: Case Law | Motion to Dismiss contained multiple fictitious case authorities; Plaintiff could not locate nine cited cases and alerted defendants; Court cited 'citation of fictitious legal authority' as grounds for show-cause. || Misrepresented: Case Law | Defendants mischaracterized valid legal authority in the Motion to Dismiss; Court included these misrepresentations in its show-cause order. || Misrepresented: Other | Defendants filed a motion to amend without disclosing the presence of the fictitious citations, which the Court treated as an attempt to mislead the Court about the reason for amendment.

Court: D. MarylandParty: Lawyer

Harms: Hallucination in legal filings

16 DEC 2025 · Court Case

Taylor v. Prince George’s County, Maryland

Misrepresented: Case Law | Plaintiffs cited Arnold v. Burger King Corp., 719 F.2d 63, 65 (4th Cir. 1983) as a per curiam opinion reversing a fee award; the court notes Arnold is a real case but not per curiam and it affirmed a fee award. || Misrepresented: Case Law | Plaintiffs cited "Bruce & Tanya & Assocs., Inc. v. Board of Supervisors, 795 F. App'x 157, 165-66 (4th Cir. 2019)" but 795 F. App'x 157 is Wilborn v. Mansukhani and Bruce & Tanya's correct reporter citation is different and its holding was misstated. || False Quotes: Case Law | Plaintiffs quoted language attributed to EEOC v. Great Steaks, Inc., 667 F.3d 510, 516 (4th Cir. 2012) (e.g., 'fees for defendants appropriate only in "egregious cases"'), but the opinion does not contain the quoted language.

Court: D. MarylandParty: Lawyer

Harms: Hallucination in legal filings

17 NOV 2025 · Court Case

Neal v. Frayer

Fabricated: Case Law | Plaintiffs cited and purported to quote a D. Md. case 'Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007)' which the Court could not locate; AI output likewise fabricated detailed content for this nonexistent opinion. || Misrepresented: Case Law | Counsel cited 'Brown v. Daniel Realty Co., 922 A.2d 1146, 1155–56 (Md. Ct. Spec. App. 2007)' — reporter/pagination matches a Connecticut opinion and the Maryland Brown opinion (949 A.2d 6 (Md. App. 2008)) does not support the proposition cited. || Misrepresented: Case Law | A citation provided by Plaintiffs (reported as Gottfredson) corresponds instead to Brenner v. Heavener, 492 F. Supp. 2d 399 (S.D.N.Y. 2007); Plaintiffs misattributed/substituted a different case and jurisdiction. || Misrepresented: Case Law | Counsel cited Adams v. Rice, 40 F.3d 72 (4th Cir. 1994) as supporting a collateral estoppel point though the opinion addresses IFP dismissal under §1915 and does not discuss collateral estoppel. || False Quotes: Case Law | Counsel placed a parenthetical quote attributed to Jones v. Buchanan, 325 F.3d 520 (4th Cir. 2003) ('a minimal level of force' can violate rights) that does not appear in the opinion; the opinion instead involved substantial force.

Court: D. MarylandParty: Lawyer

Harms: Hallucination in legal filings

29 OCT 2025 · Court Case

Mezu v. Mezu

Fabricated: Case Law | Brief contained multiple fictitious case citations generated by AI (cases that did not exist). Court found citations were fabricated and not verifiable. || Misrepresented: Case Law | Brief cited existent cases that did not stand for the propositions for which they were cited (misrepresentation of precedent). || False Quotes: Case Law | Brief included misquoted passages and quotations attributed to cases that were inaccurate.

Court: CA MarylandParty: LawyerTool: ChatGPT

⚠ Professional sanction imposed

Harms: Hallucination in legal filings

19 SEP 2025 · Court Case

United States v. Malik

False Quotes: Doctrinal Work | Purported quote from an upcoming U.S. Sentencing Guidelines amendment instructing courts to consider inability to obtain professional license; court found the amendment does not contain that language. || Fabricated: Legal Norm | Citations to several state administrative codes that either do not exist or do not contain the attributed prohibition on re-licensure while on supervised release.

Court: D. MarylandParty: Pro Se Litigant

Harms: Hallucination in legal filings

16 MAY 2024 · Law / Act

Maryland Senate Bill 360

Allocates $500,000 to Morgan State University's Center for Equitable AI and Machine Learning Systems, with funds restricted from transfer to other purposes and reverting to the General Fund if unspent.

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09 MAY 2024 · Law / Act

Maryland House Bill 1128

Establishes the Talent Innovation Program to enhance AI job training using innovative financing. Creates a nonlapsing Talent Innovation Fund to support the program, including AI sector initiatives. Allows fund investments and requires annual reporting to government officials starting in 2025.

Financial Services ·Education ·Health & Life Sciences ·+2legiscan.com ↗

09 MAY 2024 · Law / Act

Maryland Senate Bill 1068

Requires the Maryland Department of Information Technology to evaluate AI's potential in developing a statewide virtual 3–1–1 portal for nonemergency government information and services, and if feasible, prioritize its creation by July 1, 2024.

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25 APR 2024 · Law / Act

Maryland House Bill 1390

Requires the Interagency Commission on School Construction to report on the eligibility for school construction funding for AI weapon detection systems by December 15, 2024.

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08 JAN 2024 · Executive Order

Maryland State Executive Order 01.01.2024.02

Establishes an AI Subcabinet to ensure responsible AI use by Maryland state agencies, promoting principles of fairness, transparency, and innovation, while safeguarding privacy and security. Requires development of an AI Action Plan and training programs for state employees.

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08 MAY 2023 · Law / Act

Maryland House Bill 622

Establishes a grant program for small and medium-sized manufacturers to adopt Industry 4.0 technologies, including AI. Allocates grants competitively, requiring matching funds. Creates a special fund for grants. Mandates annual budget appropriations to support the program until 2028.

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01 JUL 2021 · Other

Maryland 2020 HB49

Requires jurisdictions using pretrial risk scoring instruments for release eligibility to conduct independent validation studies every 3-5 years. Establishes a grant fund for eligible counties to set up or improve pretrial services and conduct these validations.

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