Maryland · federal district court · 2025

Menk v. The Mitre Corporation

District Court, D. Maryland, 19 December 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · D. Maryland

  1. Court. District Court, D. MarylandCOURT
  2. Level. federal district courtLEVEL
  3. Date. 19 December 2025DATED
  4. Docket. No. 1:23-cv-00053DOCKET
  5. Judge. Julie Rebecca RubinJUDGE
  6. Documents. one document, 6 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 131, 19 December 2025 · source · PDF · 3 pages

Docket text. ORDER re: 130 125 Hallucinated Case Citation. Signed by Judge Julie Rebecca Rubin on 12/19/2025. (ols, Deputy Clerk) (Entered: 12/19/2025)

(ECF No. 125.) Plaintiffs filed a response to the court’s order advising that Plaintiffs’ counsel could not locate the case in question and requesting five days to investigate the matter and provide an explanation to the court ; the court granted that request. (ECF No.

June 2, 2020). 2 Collins’s ChatGPT inquiry supplied the “hallucinated” 2 case citatio n along with other materials, which he then provided to another attorney that ultimately drafted Plaintiffs’ Response pursuant to a co-counsel agreement. Id.

To be sanctionable, a legal argument must have “absolutely no chance of success under the existing precedent.” Hunter, 281 F.3d at 153. “Rule 11 requires a district court to order counsel ‘to show cause why conduct specifically described in the order has not violated Rule 11(b)’ prior to imposing sua sponte sanctions in order to allow counsel to respond to specific asserted Rule 11 violations.” In re 2 “Fake or nonexistent legal citations typically are the result of AI ‘hallucinations.’” Mezu v. Mezu, No.

11 advisory committee’s note to 1993 amendments ). “ Courts within the Fourth Circuit have issued sua sponte show cause orders where a party appears to have ‘ cited to fictitious cases and misrepresented the holding of various cases ’ in a filing. ” Neal v. Frayer , No.

In this discrete instance, the court will not issue a Rule 11 show cause order as to Mr. Collins’s citation to a hallucinated case. The court observes that Mr.

Moreover, the court is satisfied that display of this error on the public docket serves as ampl e deterrent again st future conduct of this nature. That notwithstanding, the court advises that should Plaintiffs’ counsel engage in similar conduct in the future (i.e., citation to hallucinated authorities or the like), the court will issue an order to show cause why he should not face sanctions under Rule 11 and/or attorney misconduct referral. December 19, 2025 /s/ Julie R.

What the text mentions

Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.

Where this fits

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More from District Court, D. Maryland, from Maryland, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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