A federal judge is considering sanctions against a prominent law firm defending Alabama’s troubled prison system after lawyers cited four completely fabricated AI-generated court cases .
The firm Butler Snow, which has earned millions defending the state’s corrections department, now faces potential fines and other penalties after attorney Matthew Reeves used ChatGPT to find case citations that turned out to be entirely fictional.
The humiliating discovery occurred when Frankie Johnson, a William E. Donaldson prison inmate in the Birmingham area, sued the prison. Johnson alleged he was stabbed as many as 20 times over 18 months in prison, including cases where the attacks were enabled or assisted by prison guards.
AI-Generated Fake Citations Land Lawyers in Hot Water in Alabama Prison Case
Johnson sued Alabama prison authorities in 2021 with allegations of systemic brutality, understaffing, overcrowding, and corruption within the state prison system. The office of the Alabama attorney general hired Butler Snow to represent the case, namely William Lunsford, who heads the firm’s constitutional and civil rights litigation practice.
The fake citations surfaced during a routine scheduling dispute. Johnson’s lawyers objected to proposed deposition dates, saying they needed additional documents first. Butler Snow pushed back, arguing that case law required expedited depositions of incarcerated plaintiffs.
To support their position, the firm cited four cases in a May 7th court filing. The problem? None of them existed.
One citation referenced “Kelley v City of Birmingham” from 2021, but the only real case with that name was decided by Alabama’s Court of Appeals in 1939 about a speeding ticket. The other three citations were equally bogus, though they resembled real case names closely enough to initially fool casual observers.
Johnson’s attorneys quickly spotted the fabrications and filed a motion calling them out. They suggested the fake citations came from “generative artificial intelligence” – a suspicion that proved correct.
U.S. District Judge Anna Manasco scheduled an emergency hearing, writing that she had conducted “independent searches for each allegedly fabricated citation, to no avail.” At Wednesday’s hearing, she made clear her frustration with the growing trend of AI-generated legal fiction making its way into courtrooms.
“The current case is proof positive that those sanctions were insufficient,” Manasco told the lawyers, referring to previous penalties handed down to attorneys nationwide for similar mistakes. “If they were, we wouldn’t be here.”
Attorney Faces Sanctions for AI-Hallucinated Citations
Reeves took full responsibility during the hearing, explaining that he had used ChatGPT while reviewing a junior colleague’s work. Looking for citations to support “well-established points of law,” he said the AI tool “immediately identified purportedly applicable citations.” But in his “haste to finalize the motions,” he failed to verify the cases through legal databases like Westlaw or Pacer.
“I sincerely regret this lapse in diligence and judgment,” Reeves wrote in a court declaration. “I take full responsibility.”
Butler Snow attorneys were “effusively apologetic” during the hearing and said they would accept whatever sanctions the judge deemed appropriate. They pointed to existing firm policies requiring approval before using AI for legal research, though those policies apparently weren’t followed in this case.
The incident highlights a growing problem in legal practice. Legal researcher Damien Charlotin, who tracks such cases globally, has identified 106 instances where courts have found “AI hallucinations” in legal documents. The problem appears to be accelerating, with more cases emerging in recent months than ever before.
Courts have begun imposing increasingly serious consequences. A Florida attorney was suspended for a year after citing fabricated AI cases, while a California firm was ordered to pay over $30,000 in legal fees for similar mistakes.
Despite the embarrassment, Alabama’s attorney general’s office appears to be sticking with Butler Snow. When Manasco asked about the state’s confidence in the firm, a representative responded that “Mr. Lunsford remains the attorney general’s counsel of choice.”
The firm has lucrative contracts defending multiple civil rights cases against Alabama’s corrections system, including a Justice Department lawsuit worth nearly $15 million over two years. Some state lawmakers have questioned these expenditures, but the AI citation scandal hasn’t yet shaken official support for the firm.
Manasco gave Butler Snow 10 days to explain their process for preventing future AI-generated fabrications before deciding on sanctions.
