Courts on AI / Fabricated or misquoted citations
Hicks v. City of Albany
Court of Appeals of Georgia · State appellate courts · GA · · 2026 WL 537755 · opinion
Court of Appeals of Georgia on 2026-02-26 in Hicks v. City of Albany found counsel's brief contained two citation defects, including Knight v. Pierson, involving nonexistent authorities, incorrect statutory or rule text. The court warned counsel to verify legal authorities before future filings.
- Disposition
- The court warned counsel to verify legal authorities before future filings.
- Recorded conduct
- Counsel's brief contained two citation defects, including Knight v. Pierson, involving nonexistent authorities, incorrect statutory or rule text. — outcome: warning; 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 The notice states that photographs of the stormwater drainage intake are attached, but no such photographs are included in the appellate record. 2 In his initial brief on appeal, Hicks cited two cases we could not locate, either by case name or citation. Those cases are Knight v. Pierson, Inc., 206 Ga. App. 514 (1992), and City of LaGrange v. Bolden, 261 Ga. 77 (1991). Although the City pointed out the inaccurate citation to the Knight case in its response brief, Hicks did not provide an explanation as to the cause of these fake case citations until this Court issued an order requiring Hicks to do so. Because counsel for Hicks has now taken responsibility and apologized for her actions in citing to nonexistent cases, which she believes came from an AI platform, we decline to issue sanctions. We recognize, however, that this troubling practice has become far too common and caution the bar that the failure to ensure the accuracy of filings in this Court may subject counsel to sanctions. See, e.g., Shahid v. Esaam, 376 Ga. App. 145, 149-50(1), 918 S.E.2d 198 (2025); Court of Appeals Rule 7.
Authorities cited in the passage: Counsel cited Knight v. Pierson · Counsel cited City of LaGrange v. Bolden · Those cases are Knight v. Pierson · City of LaGrange v. Bolden · Shahid v. Esaam