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Courts on AI / Fabricated or misquoted citations

Laurie Ibach and Mark Stewart v. Bruce Stewart

Supreme Court of Alabama · State supreme courts · AL · · No. SC-2025-0106 · opinion

Fabricated or misquoted citations

The Supreme Court of Alabama on 2026-04-24 doubled appellate costs, awarded $17,200, prohibited further filings without counsel, and referred counsel to the Alabama State Bar in Laurie Ibach and Mark Stewart v. Bruce Stewart. Counsel filed a submission with five fabricated case citations and three false case quotations, including Quoted Janowiak v. Tiesi as supporting a proposition.

Disposition
The motion to file supplemental briefs was denied, sanctions were imposed on Hall, Hall’s withdrawal was granted, and the appeal was dismissed.
Recorded conduct
Attorney W. Perry Hall filed opening and reply briefs with numerous invalid, inaccurate, irrelevant, misquoted, and nonexistent authorities after using an AI research tool, and continued citing nonexistent cases after admitting the issue. The court ordered $17,200 in fees and costs, double costs, a Rule 25A filing restriction, and referral to the Alabama State Bar. — outcome: regulatory referral; actor: lawyer; $17,200
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

, concurring) ("offer[ing] … preliminary thoughts about whether and how [AI-powered large language models] might aid lawyers and judges in the interpretive enterprise"). Rather, 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. And such failures often lead to problems like those in this case. In a recent case from the Northern District of Alabama, Judge Manasco set forth a few of the many harms that flow from the submission of fake legal authorities. As stated in Johnson v.

Authorities cited in the passage: Quoted Janowiak v. Tiesi as supporting a proposition

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