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AII-1000-76299
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Georgia Prosecutor Disciplined for AI-Generated Fake Legal Citations

Georgia Supreme Court disciplined prosecutor Deborah Leslie for submitting briefs containing non-existent and misattributed legal citations generated by AI software in a murder case. Leslie admitted she used AI to draft briefs without verifying the citations, leading to the court vacating a conviction denial and ordering a retrial for Hannah Payne.

5 May 2026 Β· Clayton County District Attorney's Office Β· Reliability and hallucination
5 May 2026
AII-1000-76299
Quick facts
Category
Reliability and hallucination
Country
United States
Date
5 May 2026
Drafted by
Raidu Incident Detection

What happened

Deborah Leslie, an assistant district attorney in Clayton County, Georgia, filed briefs in the Hannah Payne murder case that contained non-existent legal cases and cases that did not support the propositions asserted. Leslie acknowledged using artificial intelligence software to draft the briefs without verifying the citations before submission to the court.

Justice Benjamin A. Land noted that the trial court had denied Payne's motion for a new trial based partly on these non-existent cases cited by Leslie. The state's appellate brief also appeared to cite cases that did not stand for the propositions asserted.

Reported impact

Because of the false citations, the Georgia Supreme Court vacated the previous ruling denying Payne's motion for a new trial and sent it back to the lower court for reassessment without the misattributed citations. Hannah Payne, who had been sentenced to life without parole plus 13 years following a 2023 conviction, will now have the opportunity for a new trial.

Index analysis

Justice Land wrote that while the court has no rule against the responsible use of AI software by attorneys, citing cases that do not exist or do not support the cited propositions violates the court's rules and falls beneath expected conduct standards for Georgia lawyers.

Governance controls

As part of the ruling, the Georgia Supreme Court suspended Leslie's privilege to practice before the Georgia Supreme Court for six months and required her to complete an additional 12 hours of continuing legal education on ethics, brief writing, and use of artificial intelligence in the legal system.

Classification

Category
Reliability and hallucination
Industry
Government, security and defence
Country
United States
Harm status
Actual harm
Intent
Unintentional
Timing
Post-deployment
Harm types
Human or fundamental rights, Public interest
Failure modes
Fabricated citation, Hallucination, Overreliance
Consequences
System suspension or termination
AI systems
Unspecified AI legal drafting software

Sources and evidence

Sources not yet published

This record was researched and written by the Index from original reporting. Its sources are still being verified by an editor, and they are listed here once that check is complete. Until then the record carries no reviewer.

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