July 24, 2025


Court Disqualifies Lawyers for Using AI-Generated Fake Legal Citations

In a landmark decision, Judge Anna Manasco has forcefully removed three senior attorneys from a high-profile case, citing their use of artificial intelligence to create fictitious legal citations. The case, involving the Alabama Department of Corrections and a severely assaulted inmate, has spotlighted the emerging legal quandary surrounding AI tools in legal practices.

In May, Butler Snow, the law firm in question, faced a scathing order to show cause after the injured inmate challenged the timing of a deposition, suggesting that the Corrections' motion contained fake legal citations potentially generated by AI technology. The subsequent investigation led to a thorough 51-page ruling by Judge Manasco.

The ruling resulted in a public reprimand for the three implicated attorneys—two partners and an of counsel—along with their disqualification from the case. The court, however, spared the associates involved and the firm itself from punitive measures, recognizing their non-involvement in the misconduct.

Judge Manasco's decision highlighted the growing issue of AI "hallucinations" in legal filings, where algorithms fabricate case details to support correct legal arguments. The misuse of AI in this instance was deemed not just reckless but tantamount to bad faith, given the repeated internal and external warnings about the reliability of AI-generated content.

The court dismissed the defense argument that the AI-generated citations did not mislead anyone, stating that it was merely fortunate that the fake citations did not result in misinformation. Manasco emphasized that relying on such serendipity would only incentivize the unchecked use of AI in legal settings, potentially leading to greater mishaps.

Additionally, the court was unimpressed by claims that the media attention and subsequent embarrassment served as adequate punishment. Manasco argued that the judiciary, not the media, must enforce professional discipline to maintain legal integrity.

The most severe critique was reserved for William Lunsford, a partner at Butler Snow and deputy attorney general for Alabama, who attempted to distance himself from the controversy. The court noted Lunsford's inadequate oversight and disregard for verifying the accuracy of legal documents filed under his name.

This ruling sends a strong message to the legal community about the potential pitfalls of using AI in legal document preparation without thorough oversight and verification. As AI technology becomes more integrated into legal practices, this case may serve as a crucial precedent for establishing boundaries and responsibilities to prevent similar occurrences in the future.

The court's decision underscores the necessity for lawyers to adhere to their duty of candor and diligence, especially when employing new technological tools in legal proceedings. It serves as a stern reminder that technological advancements should not override the fundamental principles of legal practice.