Alabama Court Sanctions Attorney for AI-Generated Fake Legal Citations
The Alabama Supreme Court on Friday dismissed an appeal and sanctioned a Mobile attorney for filing briefs containing fabricated legal citations created by artificial intelligence.
Attorney W. Perry Hall represented clients Laurie Ibach and Mark Campbell in an appeal over a family trust dispute. The briefs he filed contained numerous invalid, inaccurate, and irrelevant citations to legal authorities that the court determined were "artificial intelligence 'hallucinations,' i.e., fake authorities created by an AI system."
The court ordered Hall to pay $17,200 in attorneys' fees and costs. Justices also referred him to the Alabama State Bar for potential discipline and barred him from filing anything else in the court unless another attorney in good standing signs the filing.
The Citations Were Entirely Fabricated
Hall's briefs included "nonexistent or misquoted authorities" and quotations from cases that do not appear to exist, according to court documents. The court called the improper use of AI "widespread and particularly egregious."
The underlying case involved a dispute over Bruce Stewart's alleged fiduciary duties as trustee of two living trusts. Ibach and Campbell, Stewart's niece and nephew, had appealed a summary judgment in favor of Stewart before hiring Hall.
The court and opposing party "have wasted a significant amount of time and resources reviewing and responding to the fabricated legal authorities," the majority wrote. Hall withdrew from the case after filing a reply brief stating his mistakes "will not recur."
The Core Issue: Attorney Verification
The Alabama Supreme Court identified the root cause as attorney negligence. "The problem of fake citations in court filings is the result of attorneys failing to properly research and verify the results of AI-generated citations-in short, attorney negligence in checking his or her work," the court said.
For legal professionals using AI tools, the decision underscores a basic requirement: verify every citation and claim before filing. AI systems can generate plausible-sounding but entirely false legal references. The attorney remains responsible for accuracy.
Learn more about AI for Legal professionals and how to properly implement these tools in your practice, or explore the AI Learning Path for Paralegals for guidance on document review and research automation.
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