Alabama Attorneys Sanctioned for Fabricated ChatGPT Citations in Prison Case
Three attorneys at Butler Snow admitted to using ChatGPT to generate fabricated citations in legal filings for the Alabama Department of Corrections. A federal judge disqualified them from the case, issued a public reprimand, and ordered them to notify all clients and courts of the sanctionable misconduct.
What happened
Three attorneys from Butler Snow—Matthew Reeves, William Cranford, and William Lunsford—used ChatGPT to generate citations in a motion filed on behalf of the Alabama Department of Corrections in a case involving an inmate who had been stabbed multiple times. The inmate objected to the timing of a proposed deposition and alleged that the Corrections filing "appears to have fabricated citations to legal authority in his motion for leave, 'possibly through the use of generative artificial intelligence.'"
The attorneys admitted in writing and at a hearing that the citations were generated by ChatGPT. Some citations did not exist, while others referenced a case from 1939 unrelated to the plaintiff's case, or a case that existed but in a different style than cited.
Reported impact
Judge Anna Manasco issued a 51-page order finding that the lawyers' misconduct wrought waste and harm. The court rejected arguments that the conduct caused no real damage because the underlying legal propositions were correct, stating that to accept such reasoning would "amplify the siren call of unverified AI for lawyers who are already confident in their legal conclusion."
Index analysis
ChatGPT hallucinated fake legal citations, a pattern the court described as the "wrong case, right law" phenomenon where algorithms invent fake case captions to support otherwise correct statements of law.
Governance controls
Judge Manasco disqualified all three attorneys from the case and imposed a public reprimand. The court ordered them to provide a copy of the order to all clients, opposing counsel, judges in every pending case in which they are counsel of record, and every attorney in their law firm within ten days, and to certify compliance within twenty-four hours. The court also referred the attorneys to the state bar association.
Classification
Sources and evidence
This record was researched and written by the Index, based on the following original reporting.