Attorney Sanctioned for Filing AI-Generated Murder Appeal Brief

Attorney Faces Contempt for Unverified AI Brief

A state Supreme Court has sanctioned attorney Stephen Aarons for direct contempt of court after he submitted a legal brief containing "false testimony from wholly fabricated witnesses" generated by artificial intelligence. The court's September 9 order also referred Aarons to a disciplinary board, according to reporting by Ars Technica.

The case centers on a murder appeal in which Aarons filed a brief created using ChatGPT powered by OpenAI's o3 model, released earlier in 2025. Aarons admitted during an August hearing that he failed to verify the factual claims and legal citations before filing, and never informed his client about these failures or the "multiple factual and legal misrepresentations" the brief contained.

Why It Matters

This ruling establishes clear judicial expectations that attorneys cannot outsource due diligence to AI tools, regardless of their sophistication. As generative AI becomes standard in corporate legal departments—adoption nearly doubled to 87% in the past year according to FTI Consulting—courts are drawing hard lines around professional responsibility that technology cannot diminish.

Defense of Ignorance Rejected

Aarons told the court he "assumed that it generated a bulletproof summary of proceedings" and believed the output would be accurate given AI's widespread use in legal and medical fields. The justices rejected this reasoning outright.

Justice C. Shannon Bacon expressed particular skepticism about Aarons' claim that he was unaware AI systems could produce false information—a phenomenon known as "hallucination." She noted that stories about lawyers relying on inaccurate AI-generated content appear as "above-the-fold" news daily.

"So either you buried your head in the sand—and that's a choice to do that, an intentional choice to be uninformed—or you took a gamble, and neither of those are consistent with the code of conduct," Bacon said.

The court order stated that Aarons "demonstrated a lack of remorse and a lack of concern for his client."

Broader Legal AI Tensions

The sanction arrives as the legal profession grapples with appropriate AI boundaries. Law schools have begun prohibiting AI use in classrooms to ensure students develop independent writing and analytical skills, the Financial Times reported last week.

Yet corporate adoption continues to accelerate. An August report from FTI Consulting and Relativity found that generative AI use in corporate legal departments jumped from 44% in 2024 to 87% in 2025. "Generative AI has become a fixture in the majority of legal departments," said Sophie Ross, Global CEO of FTI Technology.

The tension between rapid adoption and professional accountability will likely produce additional court rulings as judges establish precedents for AI-assisted legal work. This case makes clear that technological capability does not override the fundamental duty to verify information before presenting it to a court.

Details of the case were first reported by Ars Technica and PYMNTS.