Legal Spotlight: Maryland Law and "AI" in Mezu v. Mezu
In Mezu v. Mezu, a Maryland attorney was held to account for using artificial intelligence ("AI") without checking the legal work, which resulted in legal errors, citations to fake case law, and nonsense being submitted to the Court. Slip Op. No. 361, 2025 Md. App. Lexis 898 (Oct. 29, 2025). The Mezu precedent offers an illustration of what not to do with this new computing tool, let's call it AI, as AI makes inroads into the practice of law.
I. Mezu v. Mezu
The use of "AI" here involved a fairly routine domestic dispute concerning a divorce, with children, and property that needed to be divided up. The mother had an attorney and the father did not. The mother's counsel circulated a settlement, which seemed to resolve the issues. However at some juncture, the father appealed and sought to invalidate some of the alleged agreement, because of the stress of impending divorce, among the grounds raised. See Mezu, 2025 Md. App. Lexis at *17-*20.
While Mezu v. Mezu discusses the use of AI in legal research, the description of the attorney's conduct was notable for its negligence. The attorney admitted to the court to doing very little appellate work beforehand, yet took this appeal anyway, and did not engage in thorough legal research to advance the appeal. See Mezu, 2025 Md. App. Lexis at *11-*12. In fact, the attorney's law clerk had used a free AI legal tool to perform research and the law clerk without much oversight had prepared the bulk of the appeal defense. Neither of them appear to have known much about AI, or taken much care to understand AI, before using it to file the client's defense. They just plowed ahead. See id. at *4-*8.
As a result, the Court referred the above attorney to the professional licensing board. Id. at *16. The Maryland Appellate Court concluded, "[s]]imply stated, no brief, pleading, motion, or any other paper filed in any court should contain any citations—whether provided by generative AI or any other source—that the attorney responsible for submitting the pleading has not personally read and verified." Id. at *12-*13 (citation omitted).
II.Using AI Or Not At Law
I myself have not used AI in the law to date. Today AI is part of general search engines these days and offers summaries of information, so I have seen it there. The appearance of "AI" in 2025 and 2026 reminds me of the Ancient Greek philosopher Socrates. Socrates said, quite famously around 400 B.C. or so, he knew nothing. It's a humble definition of knowledge. Or, maybe, it's a starting place for knowledge. Musing aside, "AI" is a computer tool that produces answers and appears incapable of saying, I do not know. Thus, from a Socratic vantage point, AI is idiotic, despite appearances.
Let me return to the law and Mezu v. Mezu. The decision has a brief but insightful discussion of this very same phenomena. Citing to Chief Justice John Roberts of our U.S. Supreme Court and other recent U.S. court decisons and informative articles, AI computing systems are programmed to provide answers. As a result, AI systems are more likely to make up an answer, case decision, or quote today, than present befuddlement.
When AI makes stuff up in the law, it's often called an "AI hallucination." In other words, AI has made something up rather than admit it does not know. See Mezu, 2025 Md. App. Lexis at *8-*10. In fact, we know people who make stuff up rather than admit they do not know, and they are annoying.
Joking aside, let me summarize it another way. As I learned at a recent legal conference in October 2026, AI is a predictive modeling tool. It uses predictive tools to predict the "correct" answer. While this appears to mimic thinking because it uses language, AI is more like a vast, fast mathamatical lotto system that generates a prediction. Thus, AI results need to be checked, which of course Mezu, supra, recommends and reminds. Id. at *12-*13.
III.Takaway
As the Maryland Appellate Court says, "no brief, pleading, motion, or any other paper filed in any court should contain any citations—whether provided by generative AI or any other source—that the attorney responsible for submitting the pleading has not personally read and verified." Id. at *12-*13 (citation omitted).
In my experience in the practice of law, the "right" or "correct" answer is a complex proposition that has to consider a client's concerns within a case and beyond. The right approach looks within and beyond the four corners of any courtroom. The correct legal advice involves strategic considerations and a holistic analysis, where winning involves solving problems.
Sincerely,
Gregg H. Mosson, Esq.
Mosson Law, LLC
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