Was Abybatou Mbow v. Officer Michael Mackert et al. sanctioned over AI-generated citations?

Abybatou Mbow v. Officer Michael Mackert et al. (D. Maryland, January 28, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Order to show cause. No monetary penalty in this order.

Which AI tool was involved in Abybatou Mbow v. Officer Michael Mackert et al.?

The order in Abybatou Mbow v. Officer Michael Mackert et al. does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

January 28, 2026 · AI sanctions database

Abybatou Mbow v. Officer Michael Mackert et al.

Abybatou Mbow v. Officer Michael Mackert et al. is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: D. Maryland
Date: January 28, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Order to show cause
Penalty: No monetary penalty in this order.

Show cause

What the record shows

The court observed that many of the case citations in Plaintiff's filings, perhaps as many as half, appear to be inaccurate or could not be located, including a quotation attributed to 'Eichholz v. Camp, 36 F.4th 908' that the court matched to an unrelated Ninth Circuit case, and a citation to a page of 'Holloway v. State' that the court stated does not exist. The court directed Plaintiff to explain the errors.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · D. Maryland

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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