New Mexico Supreme Court fines lawyer $5,000 over ChatGPT-fabricated witnesses in murder appeal

Sanctions for fabricated testimony

The New Mexico Supreme Court found criminal defense attorney Stephen Aarons in direct contempt of court, issued a $5,000 fine, and referred him to a state attorney disciplinary board for investigation. Aarons, a private attorney based in Santa Fe with more than 40 years of legal experience, submitted an appeal brief containing false testimony and fabricated witnesses generated by OpenAI's ChatGPT. The justices stated that Aarons failed to verify the factual claims and legal authority in his filing before submitting it to the court. The brief was submitted on behalf of Oscar Renee Sandoval, who pleaded not guilty to the murder of Shiereen Al-Jibury before being convicted and sentenced to life imprisonment in February 2025.

Scope of the AI hallucinations

The court's findings detailed multiple instances where the artificial intelligence program fabricated witnesses and statements. Aarons admitted that the appeal brief contained false testimony attributed to fictional individuals, including Officer Michelle Amarillo, Officer Sanchez, Manal Al-Jibury, and Teresa Marquez. In addition, the brief contained fabricated claims about threats submitted under the names of Danny Stanton and Linda Stanton, as well as invented testimony concerning the shooter wearing dark pants and a white shirt. Aarons also misrepresented legal authority in case citations, going beyond standard citation errors by injecting false trial facts into a criminal proceeding.

Judicial response and hearing

Aarons stated that he fed a computer-generated transcript of the murder trial alongside related case documents into ChatGPT, believing the software would produce a reliable trial summary. During an August 21 hearing convened to examine the brief, the bench challenged Aarons on his lack of oversight and basic awareness of generative software errors. Justice C. Shannon Bacon questioned the attorney directly about his failure to recognize well-documented artificial intelligence risks.

“Counsel, do you watch the news? Do you listen to the radio? Do you read anything about what's going on in the world? Because the problem with lawyers relying on AI hallucinations is an above-the-fold story every single day.”

The supreme court concluded in its Wednesday order that Aarons exhibited a lack of remorse and failed to inform his client of the false factual and legal representations.

Reassigned appeal and disciplinary referral

Following the decision, Aarons acknowledged his failure to understand how generative artificial intelligence models invent nonexistent information.

“I am remorseful but hopeful that the disciplinary board takes into account it was an honest mistake. It is a lesson learned for all professionals who rely upon this powerful but sometimes unstable technology.”

The state of New Mexico initially moved to strike portions of Aarons' brief weeks after he submitted it in August 2025. Sandoval's murder appeal remains active in the court system, and the case was officially reassigned on 2 September 2026 to New Mexico public defender Kim Chavez Cook.