Abybatou Mbow v. Officer Michael Mackert et al. (1)
D. Maryland · Jan 28, 2026
What happened in this matter?
The court issued an Order to Show Cause directing Plaintiff's counsel to explain the inclusion of fake or inaccurate case citations and false quotations in her filings. The court identified multiple instances where counsel cited non-existent decisions, misattributed reporter information, and provided incorrect pinpoint citations.
- Why the court cared
- 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. || 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. || 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. || 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.
- Why it matters now
- This record documents a Lawyer filing issue in D. Maryland, with the listed outcome: Order to Show Cause.
Why this matter is tracked
In a civil rights action, the U.S. District Court for the District of Maryland addressed a motion to dismiss and a motion to vacate an entry of default. During the proceedings, the court identified that Plaintiff's counsel submitted filings containing numerous inaccurate, misrepresented, or fabricated case law citations and false quotations. The court specifically noted that counsel cited non-existent cases, misattributed reporter information to unrelated opinions, and relied on pinpoint pages that did not exist. Consequently, the court issued an Order to Show Cause requiring counsel to address these accusations of providing fake or inaccurate citations. The court's memorandum opinion highlights the failure of counsel to verify the existence and accuracy of legal authorities before submitting them to the court.
This record documents a Lawyer filing issue in D. Maryland, with the listed outcome: Order to Show Cause.
Record details
What the record establishes about AI use
The source document implies the use of AI for the generation of the inaccurate citations.
The court issued an Order to Show Cause in the context of a pending motion to dismiss and a motion to vacate an entry of default.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
7 citation, quotation, or authority issues are recorded in the source dataset.
- 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.
- 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.
- 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.
- 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.
Questions this record answers
- What happened in Abybatou Mbow v. Officer Michael Mackert et al. (1)?
- The court issued an Order to Show Cause directing Plaintiff's counsel to explain the inclusion of fake or inaccurate case citations and false quotations in her filings. The court identified multiple instances where counsel cited non-existent decisions, misattributed reporter information, and provided incorrect pinpoint citations.
- Why does Abybatou Mbow v. Officer Michael Mackert et al. (1) matter for legal AI risk?
- This record documents a Lawyer filing issue in D. Maryland, with the listed outcome: Order to Show Cause.
- What does the public record establish about Abybatou Mbow v. Officer Michael Mackert et al. (1)?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Abybatou Mbow v. Officer Michael Mackert et al. (1) summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
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