New Mexico Supreme Court fines attorney $5,000 over ChatGPT hallucinations in murder appeal
The New Mexico Supreme Court held defense lawyer Stephen Aarons in contempt and issued a $5,000 fine after he submitted an appellate brief containing fabricated witness testimony generated by ChatGPT.
Supreme Court contempt ruling and financial penalty
The New Mexico Supreme Court found defense lawyer Stephen Aarons in contempt of court and ordered him to pay a $5,000 fine after discovering that an appellate filing contained manufactured police statements and fictitious witness testimony generated by OpenAI's ChatGPT. The state high court determined that Aarons failed to perform the necessary verification of the factual claims presented in his formal submission, which included statements from individuals who never testified at trial. In its official ruling, the court emphasized that Aarons exhibited indifference toward his client's legal interests by submitting unchecked artificial intelligence output, and the justices ordered that his case be formally transferred to the state bar disciplinary board for further regulatory evaluation.
- Oscar Rene Sandoval is convicted of murder and sentenced to life imprisonment, after which Stephen Aarons assumes his appeal.
- The New Mexico Supreme Court orders Aarons to explain fabricated witness testimony appearing in his appellate brief.
- Public defender Kim Chavez Cook is appointed to replace Aarons as defense counsel in Sandoval's pending appeal.
- The New Mexico Supreme Court finds Aarons in contempt of court, imposes a $5,000 fine, and refers him to the state bar disciplinary board.
Trial record summarization and artificial intelligence errors
The disciplinary action stems from an appellate brief prepared on behalf of Oscar Rene Sandoval, who maintains his innocence in the murder of the mother of his children. Sandoval was convicted of murder last year and received a sentence of life imprisonment, after which Aarons took over the representation to challenge the conviction. Aarons, who manages an independent private legal office in Santa Fe, sought to streamline the appellate process by utilizing ChatGPT to generate a concise distillation of the underlying trial proceedings.
During the preparation of the appeal brief, Aarons inputted transcribed witness statements, official trial transcripts, and other evidentiary records directly into the OpenAI software, operating under the assumption that the tool would produce a dependable summary of the trial proceedings. Instead of a factual condensation, the language model produced non-existent witnesses, invented statements attributed to law enforcement officers, and specific narrative elements entirely absent from the judicial record. Among the fabricated details presented to the court was a fictitious description claiming that the perpetrator wore dark pants and a white t-shirt during the incident.
Procedural intervention and assignment of new counsel
The presence of the fabricated material prompted judicial scrutiny last month when the New Mexico Supreme Court issued a formal order requiring Aarons to explain how the unrecorded statements and synthetic witness testimony entered the legal record. Sandoval's appellate challenge remains pending before the judiciary, though Aarons is no longer directing the defense strategy. In early September, public defender Kim Chavez Cook was officially designated as Sandoval's new defense counsel to oversee the continuing appellate proceedings.
Defense attorney admissions and regulatory repercussions
Aarons acknowledged his reliance on ChatGPT and expressed remorse for submitting the unverified material, explaining to Reuters that he had not understood the magnitude and frequency of artificial intelligence hallucinations when he accepted the appellate assignment last year. Aarons stated that he hoped disciplinary authorities would recognize the context of the error.
I am contrite, but I remain hopeful that the disciplinary board will consider that this was an honest mistake.
The Santa Fe attorney indicated that the contempt citation and financial penalty serve as a serious warning to the legal community regarding uncritical reliance on generative automated platforms.
It is a painful lesson learned for all professionals who rely on this powerful but sometimes unstable technology.
OpenAI did not respond to requests for comment regarding the New Mexico ruling. The sanction against Aarons coincides with disciplinary actions across the United States legal system, where state and federal judges have penalized dozens of attorneys for submitting briefs containing legal misinterpretations and fabricated citations produced by automated tools, while several judges have faced public criticism for deploying artificial intelligence systems in their own judicial duties.
