Courts on AI / Fabricated or misquoted citations
Slay v. Ross
Court of Appeals of Georgia · State appellate courts · GA · · 2026 WL 656355 · No. No. 1:23-CV-00752- · opinion
Court of Appeals of Georgia on 2026-03-09 in Slay v. Ross found counsel's appellate brief cited four fictitious Georgia authorities, including Waller v. Waller, Johnson v. Johnson, Durden v. Barron, and In re Waitz. 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 appellate brief cited four fictitious Georgia authorities, including Waller v. Waller, Johnson v. Johnson, Durden v. Barron, and In re Waitz. — 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.
Before addressing the merits of the case, we are troubled by *2 Pertaining to the case at hand, in 2022, Slay moved for a certain irregularities in the brief filed on Slay's behalf by his downward modification of his child support payments. Slay attorney, Loletha Hale. We note that several of the cases cited then amended his petition, seeking to increase the amount of therein appear to be fictitious.2 Such “hallucinated” cases are his visitation time during spring break and certain holidays. typically a hallmark of the irresponsible use of regenerative In response, Ross requested a reduction in Slay's visitation artificial intelligence (A.I.) in legal drafting. See Shahid v. time. Following a hearing, the trial court denied Slay's petition Esaam, 376 Ga. App. 145, 146(1) (918 SE2d 198) (2025). for modification of his child support payments and visitation Although we can only surmise that the brief was drafted with time, while granting Ross's request to reduce Slay's summer the use of unchecked generative A.I., we are aware that Hale visitation time. The trial court awarded Ross attorney fees has submitted a brief with seemingly similar defects in federal under OCGA §§ 19-6-15(k)(5) and 19-9-3(g) as to these district court. See Boston v. Williams, No. 1:23-CV-00752- claims. WMR (ND Ga. Dec. 5, 2025) (2025 WL 3895555). However, Ross has not complained, nor does it appear that the fictitious Contemporaneous with his petition to modify child support cases impeded her ability to respond to Slay's arguments. and visitation, Slay filed a petition for contempt, alleging Compare Shahid, 376 Ga. App. at 147(1) (finding the use Ross had failed to reimburse him for his summer child of bogus cases and citations in appellate brief “deprived the support payments, as previously ordered. This petition was opposing party of the opportunity to appropriately respond”). consolidated and addressed at the same hearing as the And, we are unaware of the imposition of any sanctions preceding petition. The trial court denied Slay's petition for against Hale for similar conduct in this Court. We thus caution contempt. Ross moved for attorney fees under OCGA § Hale that any future filings in this Court containing fictitious 9-15-14(b), which the trial court granted, concluding that the SLAY v. ROSS., --- S.E.2d ---- (2026) petition lacked substantial justification because Slay had not Mendoza, 303 Ga. App. 758, 763(2) (695 SE2d 47) (2010)
Authorities cited in the passage: Appellant's brief cited Waller v. Waller · Appellant's brief cited Johnson v. Johnson · Appellant's brief cited Durden v. Barron · See Boston v. Williams, No. 1:23-CV-00752 · SLAY v. ROSS