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Neal v. Frayer
D. Maryland · Nov 17, 2025
MD / federalEditorial impact: lowfake citationsfabricated quotesmisrepresented authoritycivil rights
Direct answer
What happened in this matter?
Fabricated: Case Law | Plaintiffs cited and purported to quote a D. Md. case 'Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007)' which the Court could not locate; AI output likewise fabricated detailed content for this nonexistent opinion. Outcome: Warning.
- Why the court cared
- Fabricated: Case Law | Plaintiffs cited and purported to quote a D. Md. case 'Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007)' which the Court could not locate; AI output likewise fabricated detailed content for this nonexistent opinion. || Misrepresented: Case Law | Counsel cited 'Brown v. Daniel Realty Co., 922 A.2d 1146, 1155–56 (Md. Ct. Spec. App. 2007)' — reporter/pagination matches a Connecticut opinion and the Maryland Brown opinion (949 A.2d 6 (Md. App. 2008)) does not support the proposition cited. || Misrepresented: Case Law | A citation provided by Plaintiffs (reported as Gottfredson) corresponds instead to Brenner v. Heavener, 492 F. Supp. 2d 399 (S.D.N.Y. 2007); Plaintiffs misattributed/substituted a different case and jurisdiction. || Misrepresented: Case Law | Counsel cited Adams v. Rice, 40 F.3d 72 (4th Cir. 1994) as supporting a collateral estoppel point though the opinion addresses IFP dismissal under §1915 and does not discuss collateral estoppel. || False Quotes: Case Law | Counsel placed a parenthetical quote attributed to Jones v. Buchanan, 325 F.3d 520 (4th Cir. 2003) ('a minimal level of force' can violate rights) that does not appear in the opinion; the opinion instead involved substantial force.
- Why it matters now
- Cross-jurisdictional cite-swapping (Connecticut reporter attributed to Maryland) is an AI tell — verify jurisdiction alongside the cite.
Why this matter is tracked
Fabricated: Case Law | Plaintiffs cited and purported to quote a D. Md. case 'Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007)' which the Court could not locate; AI output likewise fabricated detailed content for this nonexistent opinion. Outcome: Warning.
Operational lesson
Cross-jurisdictional cite-swapping (Connecticut reporter attributed to Maryland) is an AI tell — verify jurisdiction alongside the cite.
Record details
MarylandSingle-state evidence scope
CourtD. Maryland
Jurisdictionfederal
Circuit4th Circuit
DateNov 17, 2025
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeWarning
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Warning
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiffs cited and purported to quote a D. Md. case 'Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007)' which the Court could not locate; AI output likewise fabricated detailed content for this nonexistent opinion.
- Misrepresented: Case Law | Counsel cited 'Brown v. Daniel Realty Co., 922 A.2d 1146, 1155–56 (Md. Ct. Spec. App. 2007)' — reporter/pagination matches a Connecticut opinion and the Maryland Brown opinion (949 A.2d 6 (Md. App. 2008)) does not support the proposition cited.
- Misrepresented: Case Law | A citation provided by Plaintiffs (reported as Gottfredson) corresponds instead to Brenner v. Heavener, 492 F. Supp. 2d 399 (S.D.N.Y. 2007); Plaintiffs misattributed/substituted a different case and jurisdiction.
- Misrepresented: Case Law | Counsel cited Adams v. Rice, 40 F.3d 72 (4th Cir. 1994) as supporting a collateral estoppel point though the opinion addresses IFP dismissal under §1915 and does not discuss collateral estoppel.
- False Quotes: Case Law | Counsel placed a parenthetical quote attributed to Jones v. Buchanan, 325 F.3d 520 (4th Cir. 2003) ('a minimal level of force' can violate rights) that does not appear in the opinion; the opinion instead involved substantial force.
Questions this record answers
- What happened in Neal v. Frayer?
- Fabricated: Case Law | Plaintiffs cited and purported to quote a D. Md. case 'Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007)' which the Court could not locate; AI output likewise fabricated detailed content for this nonexistent opinion. Outcome: Warning.
- Why does Neal v. Frayer matter for legal AI risk?
- Cross-jurisdictional cite-swapping (Connecticut reporter attributed to Maryland) is an AI tell — verify jurisdiction alongside the cite.
- What does the public record establish about Neal v. Frayer?
- 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 Neal v. Frayer 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
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.