New Mexico Supreme Court holds ChatGPT-using lawyer in contempt for fake witness quotes

The New Mexico Supreme Court held defense lawyer Stephen D. Aarons in direct contempt for a ChatGPT-generated appeal brief that quoted false testimony from wholly fabricated witnesses.

A state supreme court put fake AI witness quotes in a live murder appeal on the public record. The $5,000 fine is the court’s; the lawyer’s “I didn’t know AI could hallucinate” line is his.

In a 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. Direct contempt means the court punished him on the spot for conduct in that case. 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 found 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: a $5,000 fine — five thousand dollars — 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 Technica notes 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.” Hallucinate here means the model invented people and quotes. That is his statement, not a court finding.