Alabama Supreme Court sanctions, fines attorney for AI ‘hallucinations’ in filings

A gavel on an old desk on a blurred background
Attorney sanctioned, fined: The Alabama Supreme Court ruled that briefs filed by Mobile attorney W. Perry Hall contained “numerous invalid, inaccurate and/or irrelevant citations to legal authorities.” (thodonal - stock.adobe.com)

MONTGOMERY, Ala. — Alabama’s highest court on Friday dismissed an appeal because of “grossly deficient” filings made by an attorney who allegedly used artificial intelligence that created inaccurate citations.

According to the Alabama Supreme Court, Mobile attorney W. Perry Hall filed briefs on behalf of his clients, Laurie Ibach and Mark Campbell, that contained “numerous invalid, inaccurate and/or irrelevant citations to legal authorities.”

“They appear to be artificial-intelligence (AI) ‘hallucinations,’ i.e., fake authorities created by an AI system,” the court stated.

The court, in a divided decision, called the appeal “frivolous” because Hall’s filings cited dozens of cases and quotations that do not exist or were misrepresented.

Hall was ordered by the court to pay $17,200 in attorneys’ fees and costs, AL.com reported.

The Supreme Court justices also referred Hall to the Alabama State Bar for potential discipline and barred him from filing “anything else in this Court” unless another attorney -- in good standing with the state bar -- signs the filing, AL.com reported.

Hall was representing Ibach and Campbell in a family dispute over the fiduciary duties of their uncle, Bruce Stewart, who was the trustee of the Betty L. Stewart Living Trust and the Edward T. Stewart Living Trust, court documents state.

Ibach and Campbell, Stewart’s niece and nephew, respectively, previously appealed the Mobile Circuit Court’s entry of a summary judgment in favor of Stewart.

They hired Hall to represent them, AL.com reported.

According to court documents, Hall admitted that the brief he filed on behalf of his clients’ appeal misquoted two secondary sources: an article by Professor Alan Newman and a 1933 article by Professor John Dawson.

“The error arose from counsel’s first use of an AI research tool that summarized commentary not readily available through standard legal databases,” Hall said. “The tool misattributed quotes. Counsel accepts full responsibility for relying on those summaries without independently verifying the original texts. The mistake will not recur.”

The court chastised Hall for wasting the court’s time and “precious resources” expended by the courts and the opposing party in the appeal.

“This kind of egregious conduct cannot be tolerated in a judicial system whose purpose is to pursue truth and justice, but whose resources are already strained almost to the maximum,” Justice ⁠Chris McCool wrote. “This court — indeed, every court within our judicial system — must ​be able to trust the submissions of attorneys who practice before it.

“Otherwise, the precious resources available to us will eventually be strained to the breaking point.”

Justice Will Sellers dissented in part from the ruling, saying the court should ​not have ⁠dismissed the appeal, Bloomberg Law reported.

“Lawyers are agents of their clients, not principals,” Sellers said.

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