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New Mexico Lawyer Fined $5,000 After ChatGPT Hallucinations Appear in Murder Appeal

New Mexico's Supreme Court fined attorney Stephen Aarons $5,000 and held him in contempt after he submitted an AI-generated murder appeal brief containing wholly fabricated witnesses and false testimony produced by ChatGPT.

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Marc Sabatini
SEP 12, 2026 · 07:01 AM ET · 2 MIN READ
Photo by Julia A. Keirns on Unsplash

New Mexico's Supreme Court has fined attorney Stephen Aarons $5,000 and held him in contempt after an appeal he filed in a murder case was found to contain AI-fabricated witness testimony and false police testimony generated by ChatGPT.

The court issued its ruling in a Wednesday filing, citing Aarons's failure to "verify the factual claims and legal authority in his AI-generated brief." According to the filing, the brief "contained false testimony from wholly fabricated witnesses," along with "false testimony" about the shooter's clothing and appearance.

The episode came to light during an August hearing at which Aarons admitted to using ChatGPT and said he believed the tool would generate a "bulletproof summary" of the trial — a phrase that drew a sharp response from the bench.

Justice C. Shannon Bacon questioned why Aarons was unaware of the well-documented risks of AI-generated legal content. "Counsel, do you watch the news? Do you listen to the radio? Do you read anything about what's going on in the world?" Bacon said, according to Reuters. "Because the problem with lawyers relying on AI hallucinations is an above-the-fold story every single day."

Aarons issued a statement to Reuters acknowledging the error. "I am remorseful but hopeful that the disciplinary board takes into account it was an honest mistake," he said.

The case reflects a pattern that courts across the country have struggled to address as AI tools become more widely adopted in legal practice. Last year, a judge reprimanded two law firms for submitting a brief containing "numerous false, inaccurate, and misleading legal citations and quotations." Separately, lawyers representing MyPillow's Mike Lindell were fined after submitting AI-generated misquotes and fabricated citations in a brief.

AI language models, including ChatGPT, are known to "hallucinate" — confidently producing plausible-sounding but entirely fabricated information, including case citations, witness names, and legal precedents that do not exist. The phenomenon is particularly dangerous in legal contexts, where every factual and legal claim is subject to verification by opposing counsel and the court.

The New Mexico case underscores the growing gap between the pace at which legal professionals are adopting AI tools and their understanding of those tools' limitations. Bar associations in several states have begun issuing guidance on AI use, though no uniform national standard yet governs how attorneys must disclose or verify AI-assisted work product.

The contempt finding against Aarons adds institutional weight to a judicial system that has increasingly moved beyond issuing warnings and toward imposing financial and professional penalties. Whether the New Mexico disciplinary board pursues further sanctions against Aarons remains to be seen.

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━ ABOUT THE REPORTER
Marc Sabatini

Marc Sabatini is a staff writer at TechEchelon covering enterprise software, cybersecurity, and the regulatory beats that shape both. He focuses on the deal flow and policy decisions that move markets.

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