Abybatou Mbow v. Officer Michael Mackert et al. (1)
D. Maryland · Jan 28, 2026
- Jurisdiction
- federal
- Court
- D. Maryland
- Record ID
- abybatou-mbow-v-officer-michael-mackert-et-al-1-2026-01-28
- Observed outcome
- The court granted in part and denied in part the motion to dismiss and issued an Order to Show Cause regarding the inaccurate citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Lawyer filing issue in D. Maryland, with the listed outcome: Order to Show Cause.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Civil Rights
- Trial
- Ordered To Show Cause
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The source document implies the use of AI for the generation of the inaccurate citations.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.