ARTIFICIAL INTELLIGENCE [AI] IS NOT USED, IN WHOLE OR IN PART, IN PREPARING NYPPL SUMMARIES OF JUDICIAL AND QUASI-JUDICIAL DECISIONS

Aug 4, 2025

Three attorneys sanctioned by United States Federal District Court Judge after submitting AI generated citations for decisions that did not exist to the court

U.S. District Judge Anna Manasco, Northern District of Alabama, has publicly reprimanded three lawyers employed to defend the State of Alabama in a case involving the State's prison system by issuing a "Sanctions Order" after determining that the "artificial intelligence" [AI] program that had been used to prepare material submitted to the Court in the instant proceeding included certain case citations that did not, in fact, exist.* 

Such events appear to be occurring with increasing frequency as the result of the use AI programs by attorneys and others involved in preparing materials for use in litigation. In the instant situation the Court found that the case citations AI reported had not been verified before being included in the material presented to the Court for consideration.

The Court' order directed the three attorneys, among other things, "to provide a copy of the court's order to their clients, opposing counsel, and presiding judge in every pending state or federal case in which they are counsel of record; provide a copy of the court's order to every attorney in their law firm; and to comply with this requirement within ten days from the date of this order". The three attorneys must also certify to the Court that all the requirements set out in Judge Manasco's order have been satisfied within 24 hours of such compliance.

Judge Manasco's order also directed the Clerk of Court "to serve a copy of [her] order on the General Counsel of the Alabama State Bar and any other applicable licensing authorities for further proceedings as appropriate."

* Such "creativity" on the part of AI is sometimes referred to as an "AI generated hallucination".

Click HERE to access Judge Manasco's order posted on the Internet.


NYPPL Publisher Harvey Randall served as Principal Attorney, New York State Department of Civil Service; Director of Personnel, SUNY Central Administration; Director of Research, Governor’s Office of Employee Relations; and Staff Judge Advocate General, New York Guard. Consistent with the Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations, the material posted to this blog is presented with the understanding that neither the publisher nor NYPPL and, or, its staff and contributors are providing legal advice to the reader and in the event legal or other expert assistance is needed, the reader is urged to seek such advice from a knowledgeable professional.

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