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Georgia prosecutor suspended for six months after AI-generated fake citations appear in murder case ruling

Georgia prosecutor Deborah Leslie was barred from the state Supreme Court for six months after AI-generated fake citations appeared in a murder case ruling. The court vacated the order and sent the case back to the trial judge.

Georgia prosecutor disciplined for AI-generated fake citations in murder case

The Georgia Supreme Court on Tuesday disciplined prosecutor Deborah Leslie for using artificial intelligence tools without vetting the results, leading to fabricated case citations in a murder defendant's appeal. The court barred Leslie, an assistant district attorney in Clayton County, from appearing before the justices for six months and ordered her to complete additional legal education on ethics, brief writing, and proper AI use.

Leslie's AI-generated citations appeared in a proposed court order she prepared in the case of Hannah Payne, who was sentenced to life in prison plus 13 years for murder and false imprisonment. The trial judge adopted much of Leslie's proposed order-including the false citations-when denying Payne's request for a new trial.

"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," Justice Benjamin Land wrote in the court's decision.

Pattern of attorney mistakes with AI tools

State and federal courts across the country have disciplined attorneys for using generative AI for legal research and drafting without checking the output. The Georgia case is notable because it involved a prosecutor's use of AI, and the errors appeared in an actual court ruling rather than just an attorney's work product.

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 immediately respond to requests for comment.

Case sent back for new order

The Georgia Supreme Court vacated the earlier ruling and sent the case back to the trial judge, directing that a new order be issued without the fictitious citations. The justices also urged trial judges statewide to review proposed orders "with the understanding that artificial intelligence software, with all of its potential risks and benefits, may have been used."

Payne's attorney, Andrew Fleischman, said the misconduct is delaying his client's opportunity to have legitimate appellate issues decided. "Hannah Payne has strong issues for appeal," Fleischman said.

For legal professionals using AI tools in your practice, understanding proper verification procedures is essential. Consider reviewing resources on AI for Legal professionals and the AI Learning Path for Paralegals to ensure your firm's AI use meets ethical standards.

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