Skip to content

Incident Tracker / United States (state)

Ibach v. Stewart, No. SC-2025-0106 (Ala.)

·Supreme Court of Alabama·US-STATESanctions

The Supreme Court of Alabama dismissed an appeal after finding plaintiffs' counsel W. Perry Hall filed briefs whose 'widespread and particularly egregious' improper use of AI produced dozens of non-existent and misquoted authorities. It ordered Hall to pay $17,200 plus double appellate costs, barred him from further unsigned filings, and referred him to the Alabama State Bar.

Court
Supreme Court of Alabama
Date
2026-04-24
Who used the AI
Not recorded
AI tool
Not identified in the record
Conduct
W. Perry Hall, appellate counsel for the plaintiffs (Ibach and Stewart) in a trust dispute, filed briefs the Court found were riddled with misquoted and non-existent legal authorities — fabricated cases and quotations attributed to real courts that do not exist. The Supreme Court of Alabama held that 'the improper use of AI in the plaintiffs' briefs was widespread and particularly egregious,' cataloguing dozens of fictitious citations across the opening and reply briefs.
Outcome
Sanctions
Penalty
US$17,200
Regulatory outcome
Alabama State Bar: The Supreme Court of Alabama referred Hall to the Alabama State Bar for potential discipline over possible violations of the Alabama Rules of Professional Conduct. No Bar disposition is yet on record. (2026-04-24)
Status
Verified against listed sources
Last checked
2026-09-11

What was fabricated or misused

  • Ex parte Helms, 873 So. 2d 1139 (Ala. 2003) — opening brief quotation not present and trust-contest description wrong
  • Janowiak v. Tiesi, 932 N.E.2d 569, 577 (Ill. App. Ct. 2010) — opening brief quotation not found
  • In re Estate of McFarland, 167 S.W.3d 299 (Tenn. 2005) — opening brief misquoted trust-contest point
  • In re Trust of Eickhoff, 974 N.W.2d 505, 514 (Neb. Ct. App. 2022) — no such case appears to exist
  • Ex parte Seabol, 782 So. 2d 212, 216 (Ala. 2000) — opening and reply brief quotations about fiduciary concealment not found
  • McGowan v. Chrysler Corp., 631 So. 2d 842, 845 (Ala. 1993) — quoted language not found
  • Auto-Owners Ins. Co. v. Abston, 822 So. 2d 1187, 1194 (Ala. 2001) — quoted language not found and case supported the appellee
  • Alan Newman article and John Dawson 1933 article — opening brief quoted language not found in the cited secondary sources
  • Gilbert v. Gilbert, 953 So. 2d 1233, 1241 (Ala. Civ App. 2006) — neither case nor citation appears to exist
  • Sowell v. Estate of Smith, 37 So. 3d 754, 761 (Ala. 2009) — neither case nor citation appears to exist
  • Alfa Life Ins. Corp. v. Colza, 159 So. 3d 1240, 1248 (Ala. 2014) — quotation not contained in the opinion
  • Shaw v. Mobile Greyhound Park, Ltd., 605 So. 2d 243, 244 (Ala. 1992) — no record, opinion or indication of existence found
  • Ex parte Deepwater Horizon, 246 So. 3d 203, 212 (Ala. 2017) — no record, opinion or indication of existence found
  • Ex parte United Servs. Auto. Ass'n, 78 So. 3d 979, 983 (Ala. 2011) — no record, opinion or indication of existence found
  • Ex parte United Serv. Auto. Ass'n, 78 So. 3d 979, 983-84 (Ala. 2011) — reply brief case and quotation do not exist
  • Hughes v. Glover, 157 So. 2d 299, 302 (Ala. 1963) — reply brief case does not exist
  • Ex parte James, 836 So. 2d 813, 818 (Ala. 2002) — cited for fiduciary self-dealing but concerns school funding
  • Janowiak v. Tiesi, 937 N.E.2d 1259, 1273-74 (Ill. App. Ct. 2010) — reply brief quotation not found and reporter citation led elsewhere
  • Deroy v. Estate of Baron, 136 N.E.3d 748, 755 (Mass. App. Ct. 2019) — no case exists with that style and citation
  • In re Estate of Domhoff, 217 A.3d 845, 853-54 (Pa. Super. Ct. 2019) — case style not located and citation led to a criminal dissent
  • Janowiak v. Tiesi, 937 N.E.2d at 1274 — quotation about statutes of repose not found in any case the court could find
  • In re Estate of Lewy, 885 N.W.2d 345, 351 (Minn. Ct. App. 2016) — no such case and no page 351 at the cited reporter page
  • In re Estate of Ruesing, 837 N.W.2d 201, 208-09 (Mich. Ct. App. 2013) — does not exist
  • Uniform Trust Code § 603 comment — did not support the proposition asserted in the reply brief
  • Restatement (Third) of Trusts § 94 cmt. b — did not support the proposition asserted in the reply brief
  • Ex parte Bufkin, 936 So. 2d 1042, 1045 (Ala. 2006) — quoted material not found and case did not support the proposition
  • Hensley v. Poole, 910 So. 2d 96 (Ala. 2005) — did not support the asserted sibling fiduciary-power proposition
  • In re Estate of Mankowski, 132 N.E.3d 578, 587 (Ill. App. Ct. 2019) — does not exist
  • Kelly v. Conn. Mut. Life Ins. Co., 628 So. 2d 454, 458 (Ala. 1993) — parenthetical quote not in the case
  • Hall v. Hall, 903 So. 2d 78, 84 (Ala. 2004) — cited page and proposition were not supported by the case
  • Liberty Nat'l Life Ins. Co. v. Parker, 703 So. 2d 307, 308-09 (Ala. 1997) — parenthetical quote not found
  • Gilbert v. Murdock, 646 So. 2d 953, 956 (Ala. 1994) — style and reporter citation did not match any Alabama case
  • Franciscan Sisters Health Care Corp. v. Dean, 448 N.E.2d 872, 876 (Ill. 1983) — quoted material not found
  • Ex parte Ryals, 773 So. 2d 1011, 1013 (Ala. 2000) — quoted material not found
  • Kennedy v. Western Sizzlin Corp., 857 So. 2d 71, 75 (Ala. 2003) — misstated holding about denied discovery
  • Ex parte Jackson, 780 So. 2d 681, 684-85 (Ala. 2000) — did not support the appellate-briefing proposition
  • In re Estate of Mueller, 616 N.E.2d 1051, 1056 (Ill. App. Ct. 1993) — no case with that style and citation exists

What the court said

“As stated earlier, Hall, counsel for the plaintiffs, filed briefs in this appeal that contain an astounding number of invalid, inaccurate, and irrelevant citations to legal authorities.”
Supreme Court of Alabama, slip op. at 7
“At the show-cause hearing on February 4, during which Hall was represented by counsel, Hall admitted that many of the legal authorities in his briefs do not exist and that he improperly used AI to obtain those authorities.”
Supreme Court of Alabama, slip op. at 28
“In the present case, the plaintiffs' briefs cite numerous invalid, inaccurate, or irrelevant legal authorities. Most of the legal authorities in the briefs are misquoted or nonexistent.”
Supreme Court of Alabama, slip op. at 33
“Hall is hereby ordered to pay attorney fees and costs to Bruce in the amount of $17,200 (this amount includes any amount that has already been paid to Bruce);”
Supreme Court of Alabama, slip op. at 36

Timeline

  1. Plaintiffs sued Bruce in Mobile Circuit Court over the trusts.
  2. Circuit court granted Bruce summary judgment on all claims.
  3. Supreme Court ordered Hall to show cause over invalid, inaccurate and irrelevant citations.
  4. At the show-cause hearing, Hall admitted improper AI use and non-existent authorities.
  5. Trial counsel moved for leave to file supplemental briefs.
  6. Hall notified the court he had delivered a $17,200 check to Bruce's counsel.
  7. Supreme Court dismissed the appeal, denied supplemental briefs, imposed sanctions and referred Hall.

Why this case matters

Ibach is an Alabama counterpart to Noland v Land of the Free: both are appellate opinions where AI-tainted briefs led to monetary sanctions, but Alabama also dismissed the appeal and restricted future filings by the lawyer unless another Alabama lawyer signed. Compared with Johnson v Dunn, another Alabama fake-citation case, Ibach involved a state supreme court applying both Rule 38 and inherent authority. The long catalogue of false and misquoted trust-law authorities shows how AI errors can consume the appeal itself.

Practice note

Before filing an appellate brief, counsel should pull each cited authority and confirm the quoted words, reporter citation, court, year and holding. If AI was used, that check cannot stop at another AI system or a summary. When errors are found after filing, counsel should identify every affected citation, notify the court, and submit a corrected position before a show-cause order.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Ibach v. Stewart, No. SC-2025-0106 (Ala.)”, safelegalai.com/tracker/ibach-v-stewart (accessed 2026-09-16). Data: CC BY 4.0.

Report an issue with this record →