Georgia Supreme Court Confronts DA Over AI Fake Citations

A Georgia appeals filing contained fabricated legal citations that prosecutors say came from artificial intelligence, prompting an apology to the state Supreme Court and fresh questions about how lawyers verify research in high-stakes cases.

The Georgia Supreme Court is weighing an appeal for Hannah Payne, the woman accused of shooting and killing Kenneth Herring in 2019 after a vehicular incident in Clayton County. Court filings submitted by the district attorney’s office included citations and statutes that turned out to be false, drawing immediate judicial concern. That discovery forced the office to explain how the errors happened and to confront the role of new tools in legal drafting.

The prosecutor who filed the brief initially claimed the document had been altered, but that account changed as the court pressed for answers. The office had until April 2 to respond to the Supreme Court’s questions, and investigators quickly focused on whether artificial intelligence had been used in preparing the submission. Public attention sharpened because the filing included references to cases that do not exist and others that were cited in a misleading way.

Supreme Court of Georgia Chief Justice Nels Peterson pointed out there were at least five citations to cases that do not exist and at least five more that did not support the propositions for which they were cited. The prosecutor involved, Deborah Leslie, ultimately admitted to relying on AI to draft parts of the brief rather than doing the traditional verification work. That admission escalated the story from an internal filing error to a public ethics and competency issue.

The Clayton County District Attorney has apologized to the Supreme Court of Georgia, after a prosecutor admitted to relying on artificial intelligence to write court briefings, which contained made-up legal citations.

“In my almost 30-year career as an attorney and 17 years as an elected official, I never imagined a situation where I would do what I am doing now,” wrote DA Tasha Mosley, in a letter obtained by FOX 5’s Rob DiRienzo. 

Supreme Court of Georgia Chief Justice Nels Peterson said one of Mosley’s prosecutors, Deborah Leslie, filed an argument with at least five citations to cases that don’t exist, and at least five more citations to cases that do not support the proposition for which they’re cited. 

Leslie, who initially claimed the filing was altered, later admitted to using AI. 

[…] 

It’s just the latest example of attorneys relying too much on artificial intelligence, and getting caught red-handed.  

“We’ve seen judges reprimand them,” said Tom Church, a metro Atlanta trial attorney. “We haven’t seen it on this kind of platform, you know, with the Supreme Court, and we haven’t seen it from a prosecutor.” 

Church says the use of AI in high-level legal proceedings carries significant professional responsibility.

The district attorney, Tasha Mosley, issued an apology to the Supreme Court, acknowledging the gravity of submitting flawed legal authority in an appeal. The public letter underscored how unusual this situation is for a prosecutor’s office and for an elected official with a long career. That form of public contrition highlights both the reputational and legal stakes at play when court filings are questioned.

Legal professionals are increasingly debating how to incorporate AI tools without sacrificing the verification lawyers are ethically bound to perform. Artificial intelligence can speed drafting and offer research leads, but it also produces hallucinations: plausible-sounding cases or statutes that do not exist. When those hallucinations make it into filings, judges and opposing counsel are put in the position of policing basic accuracy rather than addressing the merits.

The incident in Clayton County is notable because it reached the state’s highest court and involved a prosecutor rather than a private attorney. That distinction matters to critics who worry about how public trust is affected when government lawyers rely on unvetted technology. Practitioners and bar regulators are watching to see whether sanctions, reprimands, or new guidance follow once the court completes its review.

Courtrooms have procedural rules that assume counsel verify citations and can stand behind legal assertions; those rules do not change because the drafting process is faster or more automated. The case also raises practical questions for offices that may be experimenting with new tools while lacking formal protocols for human review. For now, the Georgia filing serves as a cautionary example about the limits of automation in a field where accuracy is the baseline responsibility of every lawyer.

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