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Medium reported severity Regulatory Action

Alabama federal judge reprimands and disqualifies three Butler Snow lawyers and refers them to the state bar over ChatGPT-fabricated citations (2025)

In an incarcerated man's lawsuit against Alabama prison officials in the US District Court for the Northern District of Alabama, two motions filed in May 2025 for the defence of a former Alabama corrections commissioner contained five citations that did not exist or did not support the propositions cited. Lawyers of the Butler Snow firm, which the state retains to defend its prisons, told the court that a partner had obtained the citations from ChatGPT and had not verified them. On 23 July 2025 Judge Anna M. Manasco publicly reprimanded three of the firm's lawyers, disqualified them from the case and referred the matter to the Alabama State Bar, and ordered them to give the order to clients, opposing counsel and judges in all their pending cases. She declined to suspend them and released the firm and two other lawyers without sanction.

AI system
ChatGPT
Occurred
7 May 2025 to 23 Jul 2025
Reported
24 May 2025
Event location
Unknown
What the AI did
Communicated with the person
Reported harm
Professional HarmLegal Harm
Whose AI use
Their own AI use · Someone else’s AI use
Setting
Justice · Work
Evidence
AI involvement supported · Causal attribution established · 3 sources, 2 underlying accounts
7 claims: 6 documented, 1 reported. 3 open questions
People reported harmed
3 people

AI system as recorded: ChatGPT, which a Butler Snow partner told the court he used to search for supporting case law; the order records the citations as hallucinations of ChatGPT

What Happened

The motions. On 7 May 2025 the defence of Jefferson Dunn, a former Commissioner of the Alabama Department of Corrections sued by an incarcerated man, filed a motion for leave to depose the plaintiff; on 12 May 2025 it filed a motion to compel. Butler Snow lawyers appeared on both signature blocks. The court's sanctions order lists five problematic citations across the two motions: cases that do not exist, or real case names and numbers that do not support the stated propositions (one citation matched only a 1939 traffic-offence appeal).

How it came to light. On 15 May 2025 the plaintiff's response objected that defence counsel appeared to have fabricated citations, possibly through generative AI. The court ran its own searches for each citation without result and on 16 May ordered the signatories and the firm to show cause why they should not be sanctioned.

The AI admission. The lawyers' joint response stated that partner Matthew Reeves used ChatGPT to obtain case citations for two arguments without verifying them. Reeves declared that he performed a search on ChatGPT for supporting case law and failed to verify the citations it returned in Westlaw or PACER. The lawyer who drafted the motions declared that he had no knowledge that Reeves had used generative AI, and the practice group leader declared that he did not review the first motion and only briefly scanned the second. At the 21 May hearing, as reported by The Guardian, Reeves said he had not complied with the firm's AI policy and asked the court not to punish his colleagues.

The firm's review. Butler Snow commissioned an independent review by Morgan Lewis, whose attorneys checked more than 2,400 citations across 330 filings; the ABA Journal reports that no other incorrect case references were found.

The order. On 23 July 2025 Judge Manasco wrote that fabricating legal authority demands substantially greater accountability than the reprimands and modest fines that had become common. She publicly reprimanded Reeves, Cranford and Lunsford, disqualified them from the case, referred the matter to the Alabama State Bar and ordered them to circulate the order. In light of the independent investigation she did not suspend them, and she released the firm and two other lawyers without sanction.

Reported harm

According to the court's sanctions order of 23 July 2025, three Butler Snow lawyers were publicly reprimanded, disqualified from the case and referred to the Alabama State Bar after two motions contained citations that the lawyers confirmed were hallucinations of ChatGPT, which one of them had used and not verified.

Outcome

Resolved

Sanctions order of 23 July 2025 (Doc. 204, Johnson v. Dunn, No. 2:21-cv-01701-AMM, N.D. Ala.): public reprimand of Matthew B. Reeves, William J. Cranford and William R. Lunsford; publication of the order; disqualification from further participation in the case; referral to the Alabama State Bar and other licensing authorities; an obligation to give the order to clients, opposing counsel and presiding judges in every pending case and to every attorney in their firm. The court declined to suspend them from practice in the district and released two other lawyers and Butler Snow LLP without sanction. The outcome of the bar referral is not known.

What remains unknown

  • The outcome of the referral to the Alabama State Bar and other licensing authorities.
  • Which version of ChatGPT was used and what prompts produced the citations; the order records the partner's description of a search only.
  • Whether the disqualification delayed the plaintiff's case beyond the 30-day stay the order mentions.

What the evidence supports

AI involvement: supported. The sanctions order records that three defence lawyers confirmed in writing and at a hearing that the citations were hallucinations of ChatGPT, and quotes their joint response that partner Matthew Reeves used ChatGPT to obtain case citations for two arguments without verifying them; Reeves declared that he searched ChatGPT for supporting case law and did not verify the citations it returned. The court found five citations across the two motions that do not exist or do not support the propositions cited, and sanctioned three lawyers for those false statements. The AI output therefore reached the sanctioned filings through the partner's own exchange with ChatGPT (communicated_with). The drafting lawyer declared that he did not know generative AI had been used, and the practice group leader that he did not substantively review the legal authorities.

7 claims: 6 documented, 1 reported. What the statuses mean

Documented Two motions filed for the defendant, a former Alabama corrections commissioner, on 7 and 12 May 2025 contained five citations that did not exist or did not support the propositions for which they were cited.

Causal attribution. Established by the court's own review recorded in the sanctions order.

Documented The plaintiff's response of 15 May 2025 objected that defence counsel appeared to have fabricated citations, possibly through generative AI; the court searched for each citation without result and ordered the signatories and the firm to show cause.

Causal attribution. Procedural history documented by the order; the Guardian quotes the same show-cause order.

  • storage.courtlistener.com(opens in new tab) supports · English
    'possibly through the use of generative artificial intelligence.'; 'The next day, Plaintiff'; 'On May 14, 2025, the court granted in part and denied in part'; 'conducted independent searches for each allegedly fabricated citation, to no avail'
  • theguardian.com(opens in new tab) supports · English
    'the court has conducted independent searches for each allegedly fabricated citation, to no avail'
Documented The lawyers' response stated that partner Matthew Reeves used ChatGPT to obtain case citations for two arguments without verifying them, and Reeves declared that he did not verify the citations ChatGPT returned in Westlaw or PACER.

Causal attribution. The statements are documented by the order; the AI's role in the citations rests on the lawyers' admission, which the court accepted.

Documented On 23 July 2025 the court publicly reprimanded three lawyers, disqualified them from the case, referred the matter to the Alabama State Bar and other licensing authorities, declined to suspend them, and released two other lawyers and the firm without sanction.

Causal attribution. Established by the operative passages of the sanctions order; the ABA Journal relays it.

  • storage.courtlistener.com(opens in new tab) supports · English
    'the court PUBLICLY REPRIMANDS Mr.'; 'them from further participation in this case; and REFERS this matter to the Alabama'; 'the court exercises its discretion not to suspend them from'; 'SANCTION attorneys Daniel J. Chism and Lynette E. Potter, and the law firm'
  • abajournal.com(opens in new tab) supports · English
    'Manasco also publicly reprimanded the lawyers; referred them to the Alabama State Bar'
Documented Butler Snow commissioned an independent review by Morgan Lewis of more than 2,400 citations across 330 filings. A Morgan Lewis partner declared that the review revealed no additional fabricated citations, and the ABA Journal reports that no other incorrect case references were found.

Causal attribution. The scope of the review and the Morgan Lewis partner's declaration are documented by the order; the ABA Journal relays the finding.

Reported At the 21 May 2025 hearing, according to The Guardian, Reeves said he was aware of the limitations on AI use and had not complied with the firm's policy in these two instances, and asked the court not to punish his colleagues.

Causal attribution. Statements at the hearing as reported by The Guardian.

  • theguardian.com(opens in new tab) supports · English
    'and in these two instances I did not comply with policy'; 'I would hope your honor would not punish my colleagues'
Documented The of-counsel lawyer who drafted the motions declared that he had no knowledge that Reeves had used generative AI, and the practice group leader declared that he did not conduct a detailed or substantive review of the legal authorities in the second motion.

Causal attribution. Declarations summarised and quoted in the sanctions order.

  • storage.courtlistener.com(opens in new tab) supports · English
    'knowledge that Matt Reeves utilized generative artificial intelligence to generate'; 'Mr. Cranford is of counsel at Butler Snow'; 'or substantive review of the legal authorities'

Sources

3 sources inspected, from 2 underlying accounts. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in English by the research agent (an AI) on 2026-10-15 from the RECAP copy of the 51-page order (HTTP 200, text extracted with pdftotext). The declarations, the hearing transcript (Doc. 200) and the Morgan Lewis report it cites were not read separately. Applies to s1.

Read in full in English by the research agent (an AI) on 2026-10-15 (HTTP 200). The Guardian reports the 21 May 2025 show-cause hearing and quotes the court's order and Reeves's declaration. Applies to s2.

Read in full in English by the research agent (an AI) on 2026-10-15 (HTTP 200). The ABA Journal relays the 23 July 2025 order and Butler Snow's 19 May filing. Applies to s3.

Event countries: Unknown. Affected-person countries: Unknown. Court countries: United States.

The motions were filed in, and the sanctions imposed by, the US District Court for the Northern District of Alabama (sanctions order). Where the partner ran the ChatGPT search is not stated, so no event or affected-person country is recorded from the court seat.

Reviewed for publication 2026-10-15: Published because the federal sanctions order of 23 July 2025 documents that three defence lawyers were publicly reprimanded, disqualified and referred to the state bar over five fabricated or unsupported citations that the lawyers confirmed were hallucinations of ChatGPT, which one partner had used without verifying.

People described

Three defence lawyers at the Butler Snow firm (a partner who used ChatGPT, the of-counsel lawyer who drafted the motions, and the practice group leader) who were publicly reprimanded, disqualified and referred to the state bar; named because they are sanctioned professionals in a federal order the court directed to be published.

People reported harmed in this case

3 people

1 AI participant · 2 other people harmed

Three lawyers sanctioned in the 23 July 2025 order: the partner who declared that he used ChatGPT (counted as the AI user) and the drafting lawyer and the practice group leader, whose own use of ChatGPT is not established (counted as other people harmed). The firm and the two lawyers released without sanction are not counted; the plaintiff and the defendant are not counted as harmed by the AI use.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Tags

#alabama#federal-court#prison-litigation#lawyers#fabricated-citations#chatgpt#disqualification#bar-referral

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). Alabama federal judge reprimands and disqualifies three Butler Snow lawyers and refers them to the state bar over ChatGPT-fabricated citations (2025). AI incidents. https://nope.net/incidents/2025-alabama-federal-court-disqualifies-three-butler-snow-lawyers-over-chatgpt-fabricated-citations

BibTeX

@misc{2025_alabama_federal_court_disqualifies_three_butler_snow_lawyers_over_chatgpt_fabricated_citations,
  title = {Alabama federal judge reprimands and disqualifies three Butler Snow lawyers and refers them to the state bar over ChatGPT-fabricated citations (2025)},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-alabama-federal-court-disqualifies-three-butler-snow-lawyers-over-chatgpt-fabricated-citations}
}

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