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5 hallucinated instances lead federal choose to kick 3 Butler Snow attorneys off case
By Debra Cassens Weiss
July 30, 2025, 9:13 am CDT
Three Butler Snow attorneys might not symbolize a former corrections commissioner in Alabama as a result of they filed two motions with 5 “utterly made up” case citations produced by ChatGPT, a federal choose dominated final week. (Picture from Shutterstock)
Three Butler Snow attorneys might not symbolize a former corrections commissioner in Alabama as a result of they filed two motions with 5 “utterly made up” case citations produced by ChatGPT, a generative synthetic intelligence software, a federal choose dominated final week.
U.S. District Decide Anna M. Manasco of the Northern District of Alabama stated fabricating authorized authority “calls for considerably better accountability than the reprimands and modest fines which have turn out to be frequent as courts confront this type of AI misuse.”
Manasco additionally publicly reprimanded the attorneys; referred them to the Alabama State Bar; and ordered them to reveal the sanctions order to all shoppers, the opposing counsel and the presiding judges in each pending state and federal case during which they’re counsel of report. They’re additionally required to supply a duplicate of the order to each legal professional at Butler Snow.
However Manasco didn’t sanction the regulation agency.
“Butler Snow acted moderately in its efforts to forestall this misconduct and doubled down on its precautionary and responsive measures when its nightmare situation unfolded,” Manasco wrote.
Law360 and Reuters lined Manasco’s July 23 choice.
Manasco discovered that three out of 5 attorneys who signed the movement have been answerable for the errors. They included associate and assistant observe group chief Matthew B. Reeves, who stated at a show-cause listening to the faux citations have been resulting from his use of ChatGPT. A second sanctioned lawyer was concerned within the drafting course of, and a 3rd was the observe group chief.
The citations hallucinated by ChatGPT both don’t exist or don’t stand for the proposition for which they have been cited, Butler Snow stated in a Could 19 submitting. The agency apologized for the error and stated the usage of AI violated the agency’s coverage.
Butler Snow additionally employed Morgan, Lewis & Bockius to overview all case citations involving the 5 attorneys in federal courts in Alabama and the eleventh U.S. Circuit Courtroom of Appeals at Atlanta since April 2023. Twenty-eight Morgan Lewis attorneys reviewed greater than 2,400 separate authorized citations throughout 330 filings. No different situations of incorrect case references have been discovered.
The attorneys have been defending a former commissioner for the Alabama Division of Corrections in an inmate lawsuit alleging that he was not shielded from repeated stabbings.
Reeves and Butler Snow basic counsel Benjamin M. Watson didn’t instantly reply to ABA Journal emails searching for remark. Nor did Reeves instantly reply to a Journal voicemail message.
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