Judge considers sanctions over AI-generated false citations in Alabama prison case
Attorneys at a law firm hired to defend Alabama's prison system submitted two court filings containing five false case citations generated by ChatGPT without verification. A federal judge is considering sanctions and has scheduled hearings on whether the lawyers should face penalties.
What happened
Attorneys at Butler Snow LLP, a firm hired to defend Alabama's prison system, used ChatGPT to research case law for two court filings in federal court. Partner Matt Reeves used the AI system to generate supporting citations but did not verify the information before adding it to the filings, which were signed by four attorneys including Reeves.
U.S. District Judge Anna Manasco identified five false citations across the two filings. The citations were described as "hallucinations" — incorrect citations generated by the AI system that did not correspond to actual cases.
Reported impact
Judge Manasco held a hearing on May 21, 2025 to question the attorneys about the filings and is considering sanctions including fines. Butler Snow apologized in a response to the judge, stating that using ChatGPT to obtain legal authority without verifying sources was 'against good judgment and firm policy' and had 'no excuse'.
Index analysis
Judge Manasco noted that there have been broad national warnings from courts about the use of artificial intelligence to generate legal filings because of the potential for inaccuracies. The judge conducted independent searches for each allegedly fabricated citation and found none to exist.
Governance controls
Butler Snow stated that relying on ChatGPT to research case law without verification violated firm policy. Matt Reeves stated he alone was responsible for the false citations and asked the judge not to punish his colleagues.
Classification
Sources and evidence
Sources not yet published
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