The New Mexico Supreme Court has found veteran defense attorney Stephen Aarons in direct contempt of court after he submitted a legal brief containing fabricated witness testimony created by ChatGPT. The court's order, issued Wednesday, referred Aarons to a disciplinary board for further proceedings, noting that he showed a lack of remorse and concern for his client.

What You Need to Know

This case adds another example of lawyers facing consequences for relying on artificial intelligence without verifying output. The brief included false police testimony and other made-up details regarding a murder conviction appeal. The court emphasized that lawyers bear full responsibility for content in filings, regardless of the tool used to generate it.

Forty Years of Practice Undercut by AI Misuse

Aarons, a criminal defense lawyer with more than 40 years of experience, was hired by family members of Oscar Renee Sandoval to appeal his murder conviction. Sandoval was sentenced to life in prison in February 2025 for killing Shiereen Al-Jibury, his partner and the mother of his children. In the appeal brief, Aarons included fabricated witness statements and false police testimony generated by ChatGPT.

The attorney admitted to the court that he did not verify the factual claims or legal authority in the AI-generated brief before signing and filing it. He also failed to inform his client about the errors. The court noted that Aarons demonstrated a lack of remorse and a lack of concern for his client.

Failures in Legal Oversight

The Supreme Court identified several failures in Aarons' handling of the brief. These lapses highlight the risks of adopting AI tools without proper safeguards.

  • Aarons admitted to not verifying factual claims or legal authority in the AI-generated brief.
  • He did not inform his client about the inaccuracies or the filing errors.
  • The Court found a demonstrated lack of remorse and concern for the client.

Why This Matters

This ruling sends a clear signal to the legal profession that reliance on AI tools does not exempt lawyers from their duty to review and verify every filing. Courts are increasingly seeing cases where attorneys use generative AI to draft briefs that contain hallucinations or fabricated sources. The New Mexico Supreme Court's contempt finding sets a precedent that could lead to more severe penalties in future cases, including disbarment. The decision also underscores the need for state bar associations to develop clear ethical guidelines on the use of artificial intelligence in legal practice.

Growing Pattern of AI Misuse in Courts

This is not the first instance of a lawyer facing sanctions for citing fake cases generated by ChatGPT. Federal courts in New York and other states have previously disciplined attorneys for submitting briefs that referenced nonexistent judicial opinions. The New Mexico case adds a new dimension: fabricated factual testimony about real people and events. As AI tools become more widely adopted, courts are expected to impose stricter verification requirements and harsher penalties for negligence.