Which AI tool was involved in Neal v. Frayer?

The order in Neal v. Frayer does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

November 17, 2025 · AI sanctions database

Neal v. Frayer

Neal v. Frayer 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: November 17, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Warning; no additional action taken
Penalty: No monetary penalty in this order.

Warning

What the record shows

The court found that plaintiffs' counsel cited authority that did not exist or did not stand for the propositions asserted, including a detailed AI-generated description of Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007), which the court stated does not exist. Given counsel's corrective efforts and remorse, the court declined to issue a show cause order or further sanction and instead warned counsel that future conduct of this kind would not be tolerated.

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.

Run a free review Back to the full tracker →

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.

AI sanctions database · Sample report · Pricing · Run a scan