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Incident Tracker / United States (state)

Nimat Shahid v. Sufyan Esaam (Ga. Ct. App. 2025)

·Court of Appeals of Georgia·US-STATEFine

The Georgia Court of Appeals penalized attorney Diana Lynch whose AI-hallucinated citations infected both a proposed trial-court order (adopted below) and her appellate brief — notable because fabricated cases were inserted into an actual court order. The court imposed a $2,500 frivolous-motion penalty, the statutory maximum.

Court
Court of Appeals of Georgia
Date
2025-06-30
Who used the AI
Not recorded
AI tool
generative AI
Conduct
The husband's attorney, Diana Lynch, drafted a proposed trial-court order containing two fictitious AI-generated cases that the trial court adopted, then on appeal filed a brief citing roughly eleven more hallucinated or inapposite cases.
Outcome
Fine
Penalty
US$2,500
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
Not separately recorded

What was fabricated or misused

  • Epps and Hodge case citations from the superior court's order — opinion calls them bogus but does not give full citations
  • In the Interest of J. M. B., 296 Ga. 786 (2015) — fictitious
  • Miller v. Miller, 288 Ga. 274 (702 SE2d 888) (2010) — listed as fictitious; parallel citation matched Miller v. State
  • Brown v. Brown, 264 Ga. 48 (1994) — fictitious
  • Walker v. Georgia, 309 Ga. 749 (2021) — fictitious
  • Ramos v. Ramos, 279 Ga. 487 (2005) — fictitious
  • McRae v. McRae, 263 Ga. 303 (1993) — fictitious
  • Johnson v. Johnson, 285 Ga. 408 (2009) — fictitious
  • Blasingame v. Blasingame, 249 Ga. 791 (294 SE2d 519) (1982) — real case that did not support the service-by-publication proposition
  • Wilson v. Wilson, 282 Ga. 728 (2007) — real case that did not support the stated standard of review
  • Brown v. Tomlinson, 246 Ga. 513 (1980) — real case that did not support the no-transcript proposition
  • Jones v. State, 277 Ga. 36 (2003) — real criminal case that did not support the no-transcript proposition
  • Fleming v. Floyd, 237 Ga. 76 (226 SE2d 601) (1976) — response citation appears not to exist
  • Christie v. Christie, 277 Ga. 27 (586 SE2d 57) (2003) — response citation appears not to exist
  • Mobley v. Murray County, 178 Ga. App. 320 (342 SE2d 780) (1986) — response citation appears not to exist
  • Robinson v. Robinson, 277 Ga. 75 (586 SE2d 316) (2003) — response citation appears not to exist
  • Reynolds v. Reynolds, 288 Ga. App. 688 (2008) — response citation appears not to exist

What the court said

“The trial court denied the motion, using an order that relied upon non-existent case law.”
Court of Appeals of Georgia, slip op. at 1
“Undeterred by Wife’s argument that the order (which appears to have been prepared by Husband’s attorney, Diana Lynch) is “void on its face” because it relies on two non-existent cases, Husband cites to 11 additional cites in response that are either hallucinated or have nothing to do with the propositions for which they are cited.”
Court of Appeals of Georgia, slip op. at 3
“Therefore, we impose a $2,500 frivolous motion penalty on Lynch, which is the most the law allows, pursuant to Court of Appeals Rule 7 (e) (2).”
Court of Appeals of Georgia, slip op. at 10
“This penalty shall constitute a money judgment in favor of Wife (Nimat Shahid) against Husband’s attorney (Diana Lynch), and the trial court is directed to enter judgment in such amount upon return of the remittitur in this case.”
Court of Appeals of Georgia, slip op. at 12

Timeline

  1. Court of Appeals vacated the order denying Shahid's petition because it relied on two non-existent cases.
  2. Court identified eleven additional appellee-brief citations as hallucinated or irrelevant.
  3. Court imposed the $2,500 Rule 7(e)(2) penalty against attorney Diana Lynch.
  4. Court directed the trial court to enter judgment for Shahid for that penalty.

Why this case matters

Shahid adds a state appellate version of the problem seen in Mata v Avianca: false law moved from a lawyer's draft into the court's own order. The Georgia Court of Appeals did not treat the errors as harmless research noise, because the non-existent cases prevented review of personal jurisdiction and forced a new hearing. The statutory cap also matters: the court imposed the maximum $2,500 penalty but could not order more under Rule 7(e)(2).

Practice note

A lawyer submitting a proposed order or appellate brief must check every authority against the official report or a reliable database before filing. If an opponent identifies bogus cases, the response must correct the record rather than add more citations. Fee requests in Georgia appellate briefs also need a separate motion, not a request embedded in the brief.

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, “Nimat Shahid v. Sufyan Esaam (Ga. Ct. App. 2025)”, safelegalai.com/tracker/shahid-v-esaam (accessed 2026-09-16). Data: CC BY 4.0.

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