Skip to content

Incident Tracker / United States (federal)

Johnson v. Dunn, No. 2:21-cv-01701-AMM (N.D. Ala.), 792 F. Supp. 3d 1241

·US District Court, Northern District of Alabama (Southern Division)·US-FEDSanctions

In the Northern District of Alabama, Judge Anna M. Manasco publicly reprimanded Butler Snow attorneys Matthew B. Reeves, William J. Cranford and William R. Lunsford for filing two motions containing citations hallucinated by ChatGPT, disqualified them from the case and referred them to the Alabama State Bar; no fine was imposed, the court finding fines insufficient deterrents.

Court
US District Court, Northern District of Alabama (Southern Division)
Date
2025-07-23
Who used the AI
Lawyer
AI tool
ChatGPT
Conduct
Butler Snow LLP attorneys Matthew B. Reeves, William J. Cranford and William R. Lunsford, representing former Alabama Department of Corrections Commissioner Jefferson Dunn, filed two motions containing fabricated case citations; Reeves admitted obtaining the citations from ChatGPT without verifying them, and Cranford and Lunsford signed and filed the motions without checking them.
Outcome
Sanctions
Penalty
No monetary penalty recorded
Regulatory outcome
Alabama State Bar (General Counsel) and other applicable licensing authorities: Order served on the bar for further proceedings as appropriate; reciprocal Oklahoma discipline of Reeves is tracked separately (oba-v-reeves) (2025-07-23)
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • United States v. Baker, 539 F. App’x 937, 943 (11th Cir 2013) — miscited as confirming broad discovery rights; the reporter citation led to Williams v. Morahan
  • Kelley v. City of Birmingham, 2021 WL 1118031, at *2 (N.D. Ala. Mar. 24, 2021) — cited for refusing to delay a deposition; the only matching style was a 1939 traffic case
  • Greer v. Warden, FCC Coleman I, 2020 WL 3060362, at *2 (M.D. Fla. June 9, 2020) — no such case or similar citation existed for the stated proposition
  • Wilson v. Jackson, 2006 WL 8438651, at *2 (N.D. Ala. Feb. 27, 2006) — no such case; the Westlaw number led to Douglas v. Ingram Barge Co.
  • Williams v. Asplundh Tree Expert Co., No. 3:05-cv-479, 2006 WL 3343787, at *4 (M.D. Fla. Nov. 17, 2006) — style existed, but not that citation-and-proposition combination

What the court said

“This case is before the court because incarcerated Plaintiff Frankie Johnson accused Defendant Jefferson Dunn, the former Commissioner of the Alabama Department of Corrections, of fabricating citations to legal authorities in two motions.”
US District Court, Northern District of Alabama (Southern Division), p. 1
“In simpler terms, the citations were completely made up.”
US District Court, Northern District of Alabama (Southern Division), p. 1
“Fabricating legal authority is serious misconduct that demands a serious sanction.”
US District Court, Northern District of Alabama (Southern Division), p. 2
“The Clerk of Court is DIRECTED to serve a copy of this order on the General Counsel of the Alabama State Bar and any other applicable licensing authorities for further proceedings as appropriate”
US District Court, Northern District of Alabama (Southern Division), p. 50

Timeline

  1. Dunn filed a motion for leave to depose Johnson with hallucinated discovery authorities.
  2. Dunn filed a motion to compel with another problematic citation.
  3. Johnson objected and flagged apparently fabricated citations, possibly from generative AI.
  4. The court issued a show-cause order after independent searches found no support.
  5. Counsel admitted Reeves used ChatGPT for citations without verifying them.
  6. The court held the show-cause hearing at the Hugo Black Courthouse.
  7. The court publicly reprimanded three lawyers, disqualified them and referred the matter to licensing authorities.

Why this case matters

Johnson is one of the stronger federal responses because the court rejected a fine as too weak and used reputation-facing sanctions: publication, public reprimand, disqualification and bar notice. Unlike Mid Central v HoosierVac, which imposed money on a single lawyer, Johnson applied the duty to all lawyers whose names and signatures were on the filings, while releasing the firm and two lawyers after an independent review. The order is also notable because the client was a public official and the court declined to sanction him.

Practice note

Every lawyer named on a filing needs an assignment-level sign-off for new citations, including authorities added by a supervisor. ChatGPT output should never go into a motion until someone opens the case and confirms the cited proposition. A firm's review should also check other matters promptly, but that review does not replace the filing lawyer's certification to the court.

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

  • Mata v Avianca, Inc.2023-06-22 · US District Court, Southern District of New York · SanctionsThe origin case of legal AI hallucination sanctions: two New York attorneys were fined $5,000 after citing six ChatGPT-invented cases in a personal-injury filing and persisting after the fabrications were questioned, pr…
  • Barteca Holdings LLC v. Tacobarn Newtown LLC, No. 3:26-cv-00250 (D. Conn.)2026-08-04 · US District Court for the District of Connecticut · SanctionsIn a restaurant trade-dress dispute, the US District Court for the District of Connecticut sanctioned defense counsel USD 3,500 and referred him for discipline after a brief polished with Open Law, Claude and ChatGPT mi…
  • State v. Coleman, 2026-Ohio-965 (Ohio Ct. App., 11th Dist.)2026-03-20 · Ohio Court of Appeals, Eleventh Appellate District · SanctionsAn Ohio appellate court imposed a $2,000 sanction on a criminal-appeal attorney, credited in full by his earlier settlement payment. It also removed him as counsel, struck his reopening application and referred him to d…
  • Mid Central Operating Engineers Health and Welfare Fund v. HoosierVac LLC, No. 2:24-cv-00326-JPH-MJD (S.D. Ind.)2025-05-28 · US District Court, Southern District of Indiana (Terre Haute Division) · SanctionsIn the Southern District of Indiana, Magistrate Judge Mark J. Dinsmore recommended a $15,000 Rule 11 sanction against attorney Rafael Ramirez for three briefs citing non-existent AI-generated cases and referred him to t…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Johnson v. Dunn, No. 2:21-cv-01701-AMM (N.D. Ala.), 792 F. Supp. 3d 1241”, safelegalai.com/tracker/johnson-v-dunn (accessed 2026-10-07). Data: CC BY 4.0.

Report an issue with this record →