Two attorneys—one in California and one in Alabama—are facing sanctions for submitting court filings containing fabricated legal citations generated by artificial intelligence tools. These cases mark the latest in a growing number of disciplinary actions across the U.S. as courts grapple with the challenges of generative AI use in legal practice.
AI Tools Create Legal Trouble
Generative AI has rapidly transformed the legal industry, assisting lawyers with drafting, research, and document review. However, its use also comes with risks, particularly the production of “hallucinated” information—content that appears legitimate but is entirely fictitious. In the legal field, this issue can have serious consequences, as recent court decisions have demonstrated.
Two separate rulings—one in Alabama and another in California—illustrate just how costly these mistakes can be when attorneys rely on AI without verifying its output.
The Alabama Case: $5,000 Fine and Public Reprimand
In Alabama, U.S. District Judge Terry F. Moorer sanctioned attorney James A. Johnson, fining him $5,000 and issuing a public reprimand for filing a motion filled with fake legal citations. According to court records, Johnson used an AI tool to help draft his motion but failed to confirm the authenticity of the cases it cited.
Judge Moorer noted that one of the AI-generated cases referenced a decision overturned by the U.S. Supreme Court decades ago. The court determined that Johnson had violated his professional duty of competence and diligence by not reviewing the citations before filing the document.
In addition to the monetary penalty, the judge required Johnson to reference the sanction order in all filings he submits for the next year, ensuring transparency in his ongoing and future cases. The ruling serves as both punishment and deterrent, emphasizing that courts will hold lawyers accountable for failing to fact-check AI-generated work.
Judge Moorer’s order also expressed frustration with the increasing number of similar incidents across the country. “If prior warnings and sanctions were enough, we would not be here today,” he stated, underscoring the judiciary’s growing impatience with attorneys who treat AI-generated text as reliable legal authority.
The California Case: Education and Ethics
Across the country, a separate incident unfolded in the Northern District of California, where Judge Araceli Martínez-Olguín sanctioned attorney Edward A. Quesada for submitting a brief that included false citations generated by AI.
Quesada admitted that he had used a generative AI tool to draft portions of the filing and that some citations appeared automatically in the document. The brief included two completely fictitious case citations and one questionable reference he claimed he intended to delete but “ran out of time” to remove before filing.
Judge Martínez-Olguín imposed a $1,000 fine and ordered Quesada to complete continuing legal education (CLE) courses on AI ethics and competence. The judge emphasized that lawyers must remain technologically competent and understand the limitations of any digital tool used in their practice.
The court found that Quesada violated California’s professional rules requiring attorneys to maintain up-to-date knowledge of technology relevant to their legal services.
A Pattern of AI-Related Misconduct
These rulings add to a growing list of similar cases. In New York, a lawyer faced national scrutiny in 2023 after filing a brief containing fabricated case law created by ChatGPT. The court fined him and his firm, ruling that the attorneys had failed to fulfill their duty to ensure filings were based on legitimate authorities.
More recently, a New Jersey attorney was fined $3,000 for submitting AI-generated case citations that did not exist. Legal observers say these incidents highlight a recurring theme: attorneys’ overreliance on AI systems without human verification.
The U.S. legal system operates on the principle that lawyers are officers of the court, bound by ethical rules to ensure the accuracy and integrity of all filings. When attorneys outsource that responsibility to machines—and fail to double-check the results—they risk not only financial penalties but also professional discipline and reputational harm.
Courts Send a Clear Message
Judges nationwide are making it clear that ignorance is no excuse when it comes to technology. Even though AI tools like ChatGPT and other large language models can draft coherent, seemingly well-sourced documents, their inability to distinguish truth from fiction means attorneys must verify every citation and statement before submission.
Legal experts predict that more courts will soon introduce formal guidelines or local rules governing the use of AI in filings. Some courts already require lawyers to certify that no part of their filing was generated by an AI tool without human verification.
In response to these developments, bar associations across the U.S. are urging firms to implement internal AI policies and training programs that stress ethical use, data privacy, and verification procedures.
Ethical and Practical Implications
These disciplinary actions serve as a stark reminder that while technology can be a powerful aid, it does not replace professional judgment. Lawyers who use AI responsibly can improve efficiency and reduce research time. But when used recklessly, the same technology can compromise a client’s case—and a lawyer’s career.
For
law firms, the lesson is clear: adopt AI tools with caution, create verification protocols, and train all staff members on the risks of overreliance on generative models.
A Warning for the Legal Profession
The sanctions imposed in California and Alabama signal a turning point in how courts approach AI misuse. The message from the judiciary is unambiguous: attorneys remain fully responsible for the content they file, regardless of who—or what—drafted it.
As Judge Moorer noted, professional competence in the age of AI means more than understanding the law—it also means understanding the technology that shapes it.
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