A Maryland appeals court has referred an attorney to disciplinary authorities after he submitted a brief containing fake cases generated by artificial intelligence.

In a 34-page opinion issued on Wednesday, Appellate Judge Kathryn Grill Graeff wrote that the issues in the appeal normally wouldn’t warrant issuing a decision that sets legal precedent. But she said the court needed to address a problem that’s unfolding across the United States: lawyers using AI for court filings, leading to incorrect, inaccurate or fake citations.

“We do so as a warning to others and to determine the court’s appropriate response in this case,” Graeff said.

The Appellate Court of Maryland referred Adam Hyman, a family law attorney in Bel Air who’s been licensed to practice in the state since 2008, to the Attorney Grievance Commission of Maryland.

His attorney, Ralph Sapia, could not immediately be reached on Thursday for comment.

During oral argument on Oct. 3, Hyman said he was not aware that his law office had used AI.

Hyman prepared the brief with a law clerk who had worked for him since 2021. The law clerk reported that she used AI during her research but did not know it could hallucinate cases.

Court records show that 11 of the 27 cases mentioned in the brief contained a “citation irregularity.”

“I’m not going to do anything but take responsibility for it,” Hyman said. “For me, it’s crystal clear. I submitted something that wasn’t accurate. It’s my name. I’m the only attorney in the office. That’s my responsibility.”

But Hyman also admitted that he did not read the cases cited in the brief, Graeff said.

“Instead, he relied on his law clerk, a non-lawyer, who also clearly did not read the cases, which were fictitious,” she said.

Graeff said the case appears to be the first in which a Maryland appeals court has addressed issues that take place when lawyers use AI without exercising due diligence.

Because Hyman engaged in unprofessional conduct, she said, the court had an ethical duty to respond.