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Georgia prosecutor suspended after AI-generated fake citations appear in murder case ruling
Georgia's Supreme Court suspended prosecutor Deborah Leslie for six months after she submitted AI-generated fake case citations in a murder trial. The trial judge had adopted her fabricated citations into the final ruling.
Georgia Prosecutor Disciplined for AI-Generated Fake Citations in Murder Case
The Georgia Supreme Court on Tuesday barred prosecutor Deborah Leslie from appearing before the justices for six months and ordered her to complete additional legal education after she used artificial intelligence tools to generate fabricated case citations in a murder case.
Leslie, an assistant district attorney in Clayton County, submitted a proposed court order containing "numerous fictitious or misattributed case citations" in a 2025 ruling that denied a murder defendant's request for a new trial. The trial judge adopted much of her proposed order, including the fake citations, into the final ruling.
Justice Benjamin Land wrote that "citing cases that do not exist or do not support the proposition for which they are cited is a violation of this Court's rules and falls far beneath the conduct we expect from Georgia lawyers."
Judge Adopted AI Errors Into Ruling
The case involved Hannah Payne, who was sentenced to life in prison plus 13 years for murder and false imprisonment. Leslie's AI-generated citations appeared in the proposed order urging the trial judge to deny Payne's bid for a new trial.
Leslie apologized in an earlier court filing for failing to independently verify the AI-generated citations. The Clayton County District Attorney's Office did not respond to requests for comment.
Broader Pattern of Attorney AI Misuse
State and federal courts across the country have disciplined attorneys for using generative AI tools for legal research and drafting without vetting the results. The Georgia case is rare because a prosecutor's AI errors were repeated in a court opinion itself.
The Georgia Supreme Court on Tuesday urged trial judges to review proposed orders "with the understanding that artificial intelligence software, with all of its potential risks and benefits, may have been used."
The justices vacated the earlier ruling and sent the case back to the trial judge, directing a new order be issued without fabricated citations.
Payne's attorney, Andrew Fleischman, said in a statement: "Hannah Payne has strong issues for appeal. It is a shame that the State's misconduct is now delaying her opportunity to have those issues be decided."
For legal professionals working with AI tools, the case underscores the risks of relying on generative AI for research and citation without verification. Learn more about AI for Legal professionals or explore how AI is changing legal workflows through our AI Learning Path for Paralegals.