The New Mexico Supreme Court has held a Santa Fe defense lawyer in direct contempt for filing a murder-appeal brief built on ChatGPT output that contained “false testimony from wholly fabricated witnesses.” The justices fined him $5,000, barred him from appearing before the court until disciplinary proceedings are resolved, and referred him to the disciplinary board. They also concluded that he “demonstrated a lack of remorse and a lack of concern for his client,” Ars Technica reported.
Fake officers, fake witnesses
Stephen Aarons, a criminal defense lawyer for more than 40 years, was hired to appeal the conviction of Oscar Renee Sandoval. Sandoval was sentenced to life in February 2025 for killing Shiereen Al-Jibury, his partner and the mother of his children. Aarons filed the brief in August 2025. In its order on Wednesday, Sept. 9, the court said he admitted the brief contained testimony from fabricated witnesses: “Officer Michelle Amarillo, Officer Sanchez, Manal Al-Jibury, and Teresa Marquez.” It also included false testimony attributed to real witnesses and misdescribed legal precedents. Aarons didn’t cite fake cases. He described real ones inaccurately and invented testimony.
Aarons told the court he used Rev.com to transcribe the trial. He then loaded the transcript, the record and some discovery into ChatGPT running OpenAI’s o3 model to summarize the proceedings. “I assumed that it generated a bulletproof summary of proceedings,” he said. He admitted he didn’t verify the factual claims or legal authority before signing and filing the brief, and didn’t tell his client.
“You buried your head in the sand”
Justice C. Shannon Bacon told Aarons he had violated “at least eight or nine provisions” of the code of conduct. “So counsel, do you watch the news? Do you listen to the radio? Do you read anything about what’s going on in the world? Because the problem with lawyers relying on AI hallucinations is an above-the-fold story every single day,” she said. She rejected any distinction between misdescribing a real case and citing a fake one. She also said relying on AI is no different from relying on a first-year associate who made things up: the lawyer who signs is responsible.
“You have presented briefing to the court that we cannot rely on, and your client is the one suffering because of this far more than you will ever suffer,” Bacon said. The court struck all prior briefs and ordered the public defender’s office to appoint new counsel. The appeal will proceed in the court’s 2026-27 term.
In a statement to Ars, Aarons said that at the time, “I didn’t know that AI could hallucinate facts.” He called it “an honest mistake” and “a lesson learned for all professionals who rely upon this powerful but sometimes unstable technology.” For any business using AI to summarize records, whether transcripts, contracts or case files, the lesson is the same. Every AI-generated factual claim has to be checked against the source before anyone signs off on it.
WebProNews is an iEntry Publication