Brandy Dorsey v. Walter Livramento, III
CA Maryland · May 20, 2026
- Jurisdiction
- state
- Court
- CA Maryland
- Record ID
- brandy-dorsey-v-walter-livramento-iii-2026-05-20
- Observed outcome
- The court issued a formal warning to the appellant regarding the use of fabricated and misrepresented legal authorities.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to a pro se litigant for including fabricated and misrepresented legal authorities in an informal appellate brief, likely generated by AI. The court declined to strike the brief in its entirety but warned that future use of such authorities could result in sanctions, including the striking of future filings.
The court reasoned that the submission of nonexistent or inaccurate legal authority is improper and wastes judicial resources. It noted that while it has the discretion to strike filings under Maryland Rule 1-311(c), it exercised its discretion to decline striking the brief in its entirety, opting instead to issue a formal warning regarding the impropriety of the conduct.
This case illustrates judicial scrutiny of pro se filings involving AI-generated hallucinations. It establishes that appellate courts will identify and address improper citations even when they decline to impose immediate terminal sanctions, setting a clear expectation for research verification.
Failure modes and consequences
- Fabricated Case Law
- Misrepresented Case Law
- Pro Se
- Fake Citations
- Misrepresented Authority
- Family
- AI attribution
- Implied
- Recorded tool
- Generative artificial intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a circuit court custody modification order.
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 court suspected the use of generative AI in drafting the brief.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.