Courts on AI / Fabricated or misquoted citations
Hannah Renee Payne v. The State
Supreme Court of Georgia · State supreme courts · GA · · No. S26A0459 · opinion
The Supreme Court of Georgia on 2026-05-05 vacated and remanded the trial-court order, barred the prosecutor from appearing for six months, and ordered twelve CLE hours in Hannah Renee Payne v. The State. The prosecutor and trial court filed an opposition with two fabricated case citations and two mischaracterized case citations.
- Disposition
- The trial order was vacated and remanded, and ADA Leslie’s privilege to practice before the Supreme Court of Georgia was suspended pending CLE and reinstatement.
- Recorded conduct
- ADA Leslie used artificial intelligence software in trial and appellate filings and a proposed order, leading to fake or misattributed authorities in the order, trial briefs, and appellate briefing. The court suspended her privilege to practice before it. — outcome: suspension; actor: lawyer
- 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.
1. On March 20, 2026, after oral argument in this case, this Court entered an order directing counsel for the State to file a supplemental brief explaining, among other things, how the September 12, 2025 order of the trial court denying Payne’s motion for new trial (which reflects that ADA Leslie prepared that order) came to include nine case citations that either do not exist or do not stand for the propositions for which they are cited. 1 On March 27, 2026, Clayton County ADA Leslie filed a supplemental brief and affidavit in which she acknowledged using artificial intelligence software to draft the State’s briefs in opposition to Payne’s motion for new trial and the trial court’s proposed order denying the motion for new trial. ADA Leslie acknowledged that the case citations generated by artificial intelligence software were not independently verified before inclusion in the State’s briefs or proposed order and represented that she had implemented safeguards to ensure that fictitious or misattributed authorities would not appear in any future filings.