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More and more, the professional world is utilizing artificial intelligence (“AI”) products to enhance productivity. In law, AI is used in various ways, including legal research. Most experts agree that, with proper care, AI has the potential to improve the quality of legal research, but there are also significant unintended consequences of AI which legal professionals and legal clients should be aware of. As an example, AI technologies in legal research have been known to produce “hallucinations,” which basically means citations to cases which are either nonexistent or not supportive of the cited proposition (in other words, irrelevant). If legal documents, such as motions or briefs, which use AI products during their research begin seeing incorrect citations at higher rates, this may have profound ramifications.
In the recent case of Mezu v. Mezu (2025), this issue of faulty research results based on AI assisted research came to the forefront. The mother’s counsel apparently produced a brief which contained citations to fictitious cases; the brief had been prepared using AI products, and had been only minimally inspected by mother’s counsel prior to finalization.
Let’s explore this case in more detail so we can better understand this pressing issue of AI in Maryland law.
Facts of the Case
The parties in this case, the father and mother, were married in 2011. The couple had three children before the mother originally petitioned for divorce in 2024. The parties were able to privately resolve numerous issues of the divorce, including most property related issues. The parties developed a private marital settlement agreement (MSA) which included a complete list of all property owned by both parties. The MSA was drafted by the mother’s counsel. As mentioned, the mother’s counsel produced briefs in support of the MSA which had “citation irregularities.”
The court highlighted the fact that this is one of the first substantive cases involving AI to be heard in Maryland. This means that Maryland is just now getting to make a statement on the potential implications of AI in the world of law. The court emphasized that the potential benefits of AI are quite high, but certain preparatory work will always be required.
When using AI during legal research, the approving attorney cannot sign off on any documents generated with the AI assistive research until there is sufficient due diligence. If a brief or other document contains citations to fake or irrelevant cases, this may constitute a serious professional-ethical violation and lead to heavy consequences. When an attorney signs off on a document without giving its research proper due diligence, this represents a serious form of attorney misconduct.
Ruling & Discussion
Ultimately, the appellate court decided to refer the mother’s counsel to the Attorney Grievance Commission (AGC). This is a serious outcome. The court stated that its decision rested on the totality of the circumstances involved in this case – the fact that there were multiple instances of failing to check research, multiple fake citations, etc. The court needed to take corrective action in an AI related case to ensure better results in the future.
Readers need to know that the field of legal research is evolving, and that good counsel always puts in the necessary work to ensure a polished product. As AI continues to expand, attorneys and their assistants may use AI products in various capacities, but ultimately due diligence is always required.
Contact the Murphy Law Firm for More Information
If you want to know more about using AI in legal research, the potential consequences of inexpert counsel, developing an enforceable settlement agreement, or any other pertinent topic, contact one of the family law attorneys at the Murphy Law Firm today by calling 240-219-1187.
