
9 Sep 2026
New Mexico Supreme Court holds ChatGPT-using lawyer in contempt for fake witness quotes
9–11 Sep 2026: The New Mexico Supreme Court held defense lawyer Stephen D. Aarons in direct contempt for an AI-generated appeal brief with false testimony from wholly fabricated witnesses. $5,000 fine; disciplinary referral; new counsel ordered. Court order is the primary.
Dispositional order: the New Mexico Supreme Court held defense lawyer Stephen D. Aarons in DIRECT CONTEMPT for factual and legal misrepresentations in a ChatGPT-prepared brief in State v. Sandoval — the murder appeal of Oscar Renee Sandoval. That order is the filing event.
Aarons admitted he did not verify the AI claims or legal authority before signing and filing, and that he did not inform his client of that failure or of the misrepresentations.
The court: the brief contained false testimony from wholly fabricated witnesses, including Officer Michelle Amarillo, Officer Sanchez, Manal Al-Jibury, and Teresa Marquez. It also misrepresented legal authority. The order is about fake testimony and misstated cases — not fake case citations.
Sanctions: $5,000 to the State Bar of New Mexico Client Protection Fund within 30 days; referral to the Disciplinary Board; barred from appearing before the New Mexico Supreme Court pending those proceedings; all briefing stricken; the Law Office of the Public Defender ordered to appoint new counsel. Ars: the appeal continues in the 2026–27 term.
Aarons told Ars he fed a Rev.com transcript plus the record into ChatGPT — he indicated an o3-powered version — and said he “didn’t know that AI could hallucinate facts.” That is his statement, not a court finding.
A state high-court contempt order puts AI-fabricated witness testimony in a live murder appeal on the public record — file the court’s findings and sanctions; keep Aarons’s statement as his words.
Sources
- New Mexico Supreme Court — dispositional order of direct contempt (PDF)
cdn.arstechnica.net
- Justia — State v. Sandoval, S-1-SC-40845
law.justia.com
- Ars Technica — ChatGPT-using lawyer punished for citing fake testimony
arstechnica.com
- The Verge — Lawyer fined $5K over AI-hallucinated witnesses
theverge.com
