The New Mexico Supreme Court has held attorney Stephen Aarons in contempt and imposed a $5,000 fine after discovering that a legal brief submitted in a murder conviction appeal contained entirely fabricated evidence. The court found that Aarons relied on AI to generate summaries of trial proceedings without verifying the factual accuracy of the output, leading to the inclusion of non-existent witnesses and fake police testimony.
Fabricated Evidence and AI Hallucinations
The brief, submitted in August 2025, included testimony from several wholly fabricated individuals, including Officer Michelle Amarillo, Officer Sanchez, and others. The AI-generated text also invented false details regarding the shooter's appearance and clothing, as well as fake claims of threats received by certain individuals.
Aarons admitted during an August hearing that he had fed a computer-generated transcript of the trial into ChatGPT, specifically using a version powered by the OpenAI o3 model. He testified that he assumed the tool would provide a "bulletproof summary" of the proceedings, citing the widespread adoption of AI in legal and medical fields as a reason for his trust in the system.
Judicial Reprimand and Consequences
Justice C. Shannon Bacon sharply criticized the lawyer's negligence, asking if he "watches the news" or "reads anything about what’s going on in the world," noting that AI hallucinations in legal filings have become a daily headline. The court concluded that Aarons demonstrated a lack of remorse and concern for his client, Oscar Renee Sandoval, who was sentenced to life in prison in February 2025.
As a result of the ruling, Aarons is currently barred from appearing before the New Mexico Supreme Court pending a disciplinary board investigation. The court has ordered the appointment of new legal counsel for the defendant and struck all previous briefs from the record. This case adds to a growing list of legal failures involving generative AI, following previous instances where law firms were penalized for submitting fake citations and misquotes in court filings.
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