In Birmingham, Alabama, a federal judge issued a public reprimand to attorneys from a prestigious law firm defending Alabama’s prison system for submitting court documents containing “completely fabricated” case citations generated by ChatGPT. U.S. District Judge Anna Manasco sanctioned three attorneys from Butler Snow, a law firm contracted to defend Alabama and other jurisdictions against prison system lawsuits. She specifically called out William R. Lunsford, who leads the firm’s division dedicated to prison litigation, alongside colleagues Matthew B. Reeves and William J. Cranford.
Judge Manasco sternly remarked on the gravity of fabricating legal authority, emphasizing that such serious misconduct necessitates significant repercussions. Consequently, she removed the three attorneys from the ongoing case that involved the fictional citations and ordered them to distribute the sanction order to their clients, opposing attorneys, and judges in all their other cases. Additionally, the issue has been referred to the Alabama State Bar for potential disciplinary proceedings.
Butler Snow is vastly involved in defending multiple lawsuits against Alabama’s prison system and has received over $40 million from the state since 2020, as per state financial records. During a prior hearing, the attorneys from Butler Snow openly apologized, admitting that one of their lawyers relied on artificial intelligence to identify relevant case law but failed to verify the accuracy of the information before it was incorporated into two filings submitted to federal court. It was later discovered that the citations were entirely fictional, a phenomenon often referred to as “hallucinations” produced by AI systems.
Judge Manasco expressed her disappointment, stating that these citations were entirely concocted, and using them without verification showed an “extreme degree of recklessness.” The disputed filings were part of a lawsuit brought by an inmate who had been repeatedly stabbed at the William E. Donaldson Correctional Facility in Jefferson County. This lawsuit contends that prison officials have not fulfilled their duty to protect inmates from harm.

