Lawyer Sanctioned Again Over AI-Generated Fake Citations
Matthew Reeves, a former partner at law firm Butler Snow, has been reprimanded by the Oklahoma Supreme Court for using unverified artificial intelligence citations in court filings. This marks the fourth formal sanction against Reeves for the same incident.
The Oklahoma Supreme Court said in its order Wednesday that "human diligence and review is required to ensure content and accuracy of filed documents." The court found that signing pleadings containing citations from ChatGPT without verification "shows a reckless disregard for the truth and an indifference to accuracy."
Reeves was sanctioned by an Alabama federal judge last year after he submitted court filings with fabricated legal citations in a case involving the state prison department. He has since faced public censure in Texas and Tennessee under rules that allow courts to discipline attorneys licensed in their states who have been sanctioned elsewhere.
The AI Error
In December, Reeves told the court he accepted responsibility for failing to verify five case citations generated by OpenAI's ChatGPT. "I did not fully appreciate the specific problems associated with AI usage in the context of legal research, including the danger of ChatGPT returning valid propositions of law with fabricated, non-existent citations," he said.
Reeves is no longer listed as a Butler Snow attorney on the firm's website. In response to the sanctions last year, the firm said it would conduct "additional and extensive firm-wide training on the appropriate use of artificial intelligence."
Broader Pattern in Legal Practice
Reeves' case is part of a growing trend. Courts across the country have sanctioned lawyers for submitting court filings containing non-existent legal sources, misquoted law, and fabricated case citations generated by AI tools.
Reeves said he has partnered with a University of Alabama law professor to develop an education program for law students about the risks of AI for Legal work. The professor was opposing counsel in the Alabama case where the AI errors occurred.
Reeves asked the Oklahoma court not to impose additional discipline, citing "the reputational, professional, and personal consequences I have already faced and will continue to face." The court declined that request.
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