Incident Tracker / United States (state)
State ex rel. Oklahoma Bar Association v. Reeves, 2026 OK 37
·Supreme Court of Oklahoma·US-STATEWarning
The Oklahoma Supreme Court publicly reprimanded attorney Matthew Reeves under reciprocal-discipline rules after he admitted using ChatGPT to fabricate five citations in federal filings in Johnson v. Dunn — conduct already reprimanded or censured by the bars of Texas, Tennessee, and Alabama. A rare multi-state disciplinary chain over one AI incident.
- Court
- Supreme Court of Oklahoma
- Date
- 2026-05-27
- Who used the AI
- Not recorded
- AI tool
- ChatGPT
- Conduct
- Attorney Matthew Brett Reeves used ChatGPT to generate five fabricated citations added to two motions in the federal case Johnson v. Dunn (N.D. Ala.), for which he was sanctioned. Reciprocal bar discipline followed in several states.
- Outcome
- Warning
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- State bar disciplinary authorities (Oklahoma, Texas, Tennessee, Alabama): Public reprimand by the Supreme Court of Oklahoma (27 May 2026) under reciprocal discipline, following a Texas public reprimand (4 Nov 2025), a Tennessee public censure (15 Dec 2025), and an Alabama public reprimand (6 Mar 2026). (2026-05-27)
- Status
- Verified against listed sources
- Last checked
- 2026-09-16
What was fabricated or misused
- Williams v. Asplundh Tree Expert Co., No. 3:05-cv-479, 2006 WL 3343787, at *4 (M.D. Fla. Nov. 17, 2006) — no case with that combination of style and proposition exists
- United States v. Baker, 539 F.App'x 937, 943 (11th Cir 2013) — cited for broad discovery rights, but the actual Baker case involved a criminal sentencing enhancement and the cited Federal Appendix pages did not discuss discovery
- Kelley v. City of Birmingham, 2021 WL 1118031, *2 (N.D. Ala. Mar. 24, 2021) — no federal case with that style and proposition was found
- Greer v. Warden, FCC Coleman I, 2020 WL 3060362, at *2 (M.D. Fla. June 9, 2020) — the case does not exist
- Wilson v. Jackson, 2006 WL 8438651, at *2 (N.D. Ala. Feb. 27, 2006) — no such case; the Westlaw number led to a maritime personal-injury case that did not discuss discovery
What the court said
“Respondent admitted in his response to the order to show cause from the federal court that the citations were hallucinated by ChatGPT. “In simpler terms, the citations were completely made up.””
“There is nothing inherently problematic with the use of generative artificial intelligence in preparing legal materials, so long as attorneys abide by their duty to protect client confidentiality and recall their sacred duty to verify the pleadings they sign.”
“Human diligence and review is required to ensure content and accuracy of filed documents. Signing pleadings that contain citations from generative AI that have not been verified shows a reckless disregard for the truth and an indifference to accuracy.”
“Respondent was the only attorney in the case who used AI to find citations. Respondent was the only attorney in the case who knew that he used AI. And most importantly, Respondent knew that he did not verify the citations that he added.”
Timeline
- Reeves filed a motion for leave to depose an incarcerated person.
- Reeves filed a motion to compel with additional ChatGPT citations.
- Northern District of Alabama entered its sanctions order in Johnson v Dunn.
- Texas Board of Disciplinary Appeals issued an agreed public reprimand.
- Tennessee Board of Professional Responsibility issued a public censure.
- Alabama State Bar Disciplinary Commission publicly reprimanded Reeves.
- Oklahoma Supreme Court publicly reprimanded Reeves under reciprocal discipline.
Why this case matters
Reeves extends the Mata v Avianca pattern from a single sanctions order to a multi-state licensing chain. Oklahoma did not retry the Northern District of Alabama facts; it treated the Texas, Tennessee and Alabama dispositions as reciprocal-discipline evidence. That makes the record useful for firms and lawyers admitted in several states: one AI citation failure can move through every bar where the lawyer is licensed, even when later proceedings add little new fact-finding.
Practice note
Follow the firm’s AI policy before using a public chatbot for legal research. If the tool supplies a citation, locate the decision in a recognized legal database and confirm the cited passage supports the filing. A lawyer admitted in multiple states should self-report discipline where required, but reporting does not cure the original verification failure.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “State ex rel. Oklahoma Bar Association v. Reeves, 2026 OK 37”, safelegalai.com/tracker/oba-v-reeves (accessed 2026-09-16). Data: CC BY 4.0.