Skip to main content
NOPE
Low reported severity Investigation Opened

Prosecutor: judge used ChatGPT citations in Oklahoma custody order later vacated

In November 2025 Stephens County Associate District Judge Lawrence Wheeler issued an order in a child paternity and custody case that denied one parent's request for a psychological evaluation of the other parent and reprimanded the requesting parent's attorney 'for stooping to such frivolous trial tactics'. The attorney challenged the order at the Oklahoma Supreme Court in February 2026, telling the justices that it relied on two cases that do not exist; the challenge was dismissed in March after Wheeler vacated the order, and he is no longer on the case. According to a 17 August 2026 letter from the Stephens County district attorney, Wheeler told the Oklahoma State Bureau of Investigation that he used ChatGPT for research and wrote the order himself, and that at least two citations in it produced by ChatGPT do not exist. The mother in the case told News 9 that learning the order's citations were allegedly fabricated was alarming because it concerned the custody of a child. The attorney general's office declined criminal prosecution; judicial discipline remains possible.

AI system
ChatGPT
OpenAI
Occurred
Nov 2025
Reported
9 September 2026
Event location
United States
What the AI did
Informed a human decision about the person
Reported harm
Legal HarmProfessional Harm
Whose AI use
An institution’s AI use
Setting
Justice · Relationships
Evidence
AI involvement supported · Causal attribution supported · 4 sources, 1 underlying account
5 claims: 5 reported. 4 open questions
People reported harmed
At least 2 people

AI system as recorded: ChatGPT (OpenAI), used by the judge for legal research while preparing the order

What Happened

The Oklahoman (republished through Reuters Connect by Minnesota Lawyer) reports that in November 2025, in a child paternity case, Wheeler reprimanded an attorney for asking for a psychological evaluation of the child's father, 'for stooping to such frivolous trial tactics', and cautioned that future similar filings might draw further sanctions. KFOR describes the same order as denying a request from one parent's attorney to have the other parent undergo a psychological test, supported by multiple previous Oklahoma cases the judge said backed him up. The attorney challenged the order at the Oklahoma Supreme Court in February 2026, telling the justices that Wheeler based it on two cases, Cummings v. Cimarron Elevator Co. and Hawkins v. Linhart, that do not exist. The challenge was dismissed in March after Wheeler vacated the order. In a 17 August 2026 letter to Attorney General Gentner Drummond, District Attorney Jason Hicks wrote that Wheeler told the OSBI he used ChatGPT only for research and created the order himself, but indicated that at least two of the case citations in his order, produced by ChatGPT, do not exist. The OSBI inquiry, requested by the Council on Judicial Complaints, also examined whether Wheeler offered to amend the order in exchange for dismissal of the writ and whether he eavesdropped on jury deliberations. The mother, interviewed by News 9, said her custody case had run for about three years, that her attorney found the cited cases did not exist when preparing a motion against the denial, that the judge later recused himself and apologised to her attorney, and that learning of the citations was alarming because the order concerned a child's custody. Wheeler's attorney declined to comment.

Reported harm

According to the district attorney's letter as reported by The Oklahoman and KFOR, a judge acknowledged that his custody-case order contained at least two nonexistent citations supplied by ChatGPT. The order denied a request for a psychological evaluation and reprimanded the requesting attorney. The attorney challenged it at the Oklahoma Supreme Court before it was vacated. The mother described the discovery as alarming in a News 9 interview. The order and letter have not been inspected directly.

Outcome

Ongoing

The attorney challenged the order at the Oklahoma Supreme Court in February 2026 and dismissed the challenge in March after Wheeler vacated the order; Wheeler is no longer involved in the case. At the request of the Oklahoma Council on Judicial Complaints, the OSBI investigated the judge; the investigation also covered allegations that he offered to amend the order in exchange for dismissal of the writ and that he eavesdropped on jury deliberations. District Attorney Jason Hicks recused his office and on 17 August 2026 asked the attorney general to review the OSBI report. The attorney general's office said on 2 September 2026 that the evidence did not support criminal prosecution and that the Oklahoma Supreme Court and the Court on the Judiciary have jurisdiction over judicial discipline. No disciplinary outcome has been reported. The mother told News 9 the family was taking the matter to the appeals court.

What remains unknown

  • The text of the order and whether the nonexistent citations were decisive for denying the evaluation and for the reprimand.
  • Whether any disciplinary proceeding follows from the Council on Judicial Complaints referral.
  • The current state of the custody case after the vacatur and the judge's departure from it.
  • The exact day in November 2025 on which the order was issued.

What the evidence supports

AI involvement: supported. The Oklahoman, KFOR and News 9 relay a district attorney's letter saying the judge acknowledged using ChatGPT for research and incorporating at least two nonexistent citations it produced into his order. The cited authorities were presented in support of the human judge's denial of a requested evaluation and his reprimand of the attorney. This supports informed_decision_about for the affected mother and attorney. It does not establish that ChatGPT itself decided custody or communicated with either of them. The underlying letter and order were not inspected, and whether the citations determined the outcome is unknown.

5 claims: 5 reported. What the statuses mean

Reported In November 2025, in a child paternity and custody case, Judge Wheeler issued an order denying a request by one parent's attorney for a psychological evaluation of the other parent, citing Oklahoma cases he said supported the decision.

Causal attribution. Court history as reported by The Oklahoman and KFOR and described by the mother; the order itself was not read.

  • aol.com(opens in new tab) supports · English
    'Wheeler denied a request from one of the parents' attorneys to have the other parent undergo a psychological test—and in his order denying the request, he pointed to multiple previous Oklahoma cases he said backed him up.'
  • minnlawyer.com(opens in new tab) supports · English
    'The 2025 order in a child paternity case'; 'He came under scrutiny after he reprimanded attorney [the attorney] last November in an order in the paternity case for asking for a psychological evaluation of the child’s father.'
  • news9.com(opens in new tab) supports · English
    'The issue came to light after a request for a mental evaluation was denied and a subsequent court order was filed.'
Reported According to the district attorney's 17 August 2026 letter, the judge told the OSBI that he used ChatGPT for research and wrote the order himself, and indicated that at least two case citations in the order, produced by ChatGPT, do not exist.

Causal attribution. The judge's own statement to investigators as relayed in the district attorney's letter; all four reports rely on that letter, which was not read. The judge's attorney declined to comment.

  • minnlawyer.com(opens in new tab) supports · English
    'The judge told the OSBI he only used ChatGPT for research and created the order himself, DA Jason Hicks wrote. The judge, however, also “indicated that at least two of the case citations included in his order and produced by ChatGPT do not exist.”'
  • aol.com(opens in new tab) supports · English
    'Stephens County District Attorney Jason Hicks says Wheeler admitted to OSBI agents he cited "at least two" cases ChatGPT fed him that "do not exist."'
  • news9.com(opens in new tab) supports · English
    'Hicks wrote that Wheeler acknowledged using case citations generated by ChatGPT and that at least two citations included in the order did not exist.'
  • hoodline.com(opens in new tab) supports · English
    'Associate District Judge Lawrence Wheeler used OpenAI's ChatGPT for research while drafting the order, which cited two cases that do not exist, according to state records.'
Reported The order reprimanded the attorney who had asked for a psychological evaluation of the child's father 'for stooping to such frivolous trial tactics' and warned of further sanctions; that attorney challenged it at the Oklahoma Supreme Court in February 2026, saying it relied on two nonexistent cases, and dismissed the challenge in March after Wheeler vacated the order. The mother told News 9 that her attorney at the time challenged the ruling.

Causal attribution. The Oklahoman's account of the court filings and the mother's account to News 9; the Supreme Court filings were not read.

  • minnlawyer.com(opens in new tab) supports · English
    'The judge issued the reprimand “for stooping to such frivolous trial tactics” and cautioned that future similar filings may be subject to further sanctions.'; '[The attorney] challenged the order at the Oklahoma Supreme Court in February. He told justices that Wheeler based his order on two cases, Cummings v. Cimarron Elevator Co. and Hawkins v. Linhart, that do not exist.'; '[The attorney] dismissed his challenge in March after Wheeler vacated the order. Wheeler is no longer involved in the paternity case.'
  • news9.com(opens in new tab) supports · English
    'She said her attorney at the time challenged the ruling and began reviewing the legal authorities cited in the order.'
Reported The mother told News 9 that learning the citations were allegedly fabricated was alarming because the order involved the custody of a child, and that the judge later recused himself from her case and apologised to her attorney.

Causal attribution. The mother's first-person account in a broadcast interview.

  • news9.com(opens in new tab) supports · English
    '[The mother] said learning the citations were allegedly fabricated was alarming because the order involved the custody of a child.'; '“Then it became very concerning to me that somebody would do something like that over a child custody case,” she said.'; '“He then turned around and decided to recuse himself from my case,” she said. “He called my attorney that I had at the time and apologized to him.”'
Reported The OSBI investigated the judge at the request of the Council on Judicial Complaints, including allegations that he offered to amend the order in exchange for dismissal of the writ and that he eavesdropped on jury deliberations; the attorney general's office said the evidence did not support criminal prosecution and that judicial discipline rests with the Oklahoma Supreme Court and the Court on the Judiciary.

Causal attribution. District attorney's letter and attorney general's statement as reported; no disciplinary finding has been made.

  • minnlawyer.com(opens in new tab) supports · English
    'The OSBI investigated the judge at the request of the Oklahoma Council on Judicial Complaints.'; 'The OSBI also looked into allegations “that Judge Wheeler offered to amend the order in exchange for a dismissal of a writ seeking relief from the Oklahoma Supreme Court” and that he “eavesdropped on jury deliberations,” the DA disclosed in the letter.'; 'Prosecutors in the AG’s office “thoroughly reviewed the results of the investigation and determined the evidence does not support a criminal prosecution,” the AG’s press secretary, Leslie Berger, said on Sept. 2.'
  • news9.com(opens in new tab) supports · English
    'The Criminal Justice Division of the Attorney General’s Office thoroughly reviewed the results of the investigation and determined the evidence does not support a criminal prosecution. The Oklahoma Supreme Court and the Court on the Judiciary possess ultimate jurisdiction over disciplinary actions for allegations of inappropriate behavior by judges regardless of whether the behavior constitutes a violation of a criminal statute.'

Sources

4 sources inspected, from 1 underlying account. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

The Oklahoman's report (USA TODAY Network via Reuters Connect) as republished by Minnesota Lawyer; read in full from the Wayback capture of 10 September 2026 because the live page returned 403. Its ChatGPT-admission passages relay the district attorney's letter; its account of the reprimand, the Supreme Court challenge and the vacatur draws on court filings and the attorney. Reinspected in the retained complete English body on 2026-10-06. All sources share the district-attorney-letter chain for AI involvement, so grouped conservatively together; the News 9 maternal interview is separate testimony about her experience, not a second verification of AI use. Applies to s1.

KFOR (Oklahoma City) report syndicated on AOL, read in full on 2026-09-29. Its account of the ChatGPT admission relays the same district attorney letter. Reinspected in the retained complete English body on 2026-10-06. All sources share the district-attorney-letter chain for AI involvement, so grouped conservatively together; the News 9 maternal interview is separate testimony about her experience, not a second verification of AI use. Applies to s2.

News 9 (Griffin Media) interview with the mother, read in full on 2026-09-29. Its description of the ChatGPT admission also relays the district attorney's letter; the mother's own account is independent of it. Reinspected in the retained complete English body on 2026-10-06. All sources share the district-attorney-letter chain for AI involvement, so grouped conservatively together; the News 9 maternal interview is separate testimony about her experience, not a second verification of AI use. Applies to s3.

Hoodline rewrite of the Reuters report, read in full on 2026-09-29. Reuters relays the same district attorney letter. Reinspected in the retained complete English body on 2026-10-06. All sources share the district-attorney-letter chain for AI involvement, so grouped conservatively together; the News 9 maternal interview is separate testimony about her experience, not a second verification of AI use. Applies to s4.

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

The Oklahoman, KFOR and News 9 locate the order and proceedings in Stephens County, Oklahoma, and the Oklahoma Supreme Court. These establish the event and court countries as US. News 9 calls the interviewee a Stephens County mother but gives no explicit residence evidence for either counted person, so affected_person_countries is unknown.

Reviewed for publication 2026-10-06: This reported event connects specific ChatGPT-generated citations to an adverse order issued by a human judge. The Oklahoman and KFOR describe their use in the order, The Oklahoman reports the attorney's reprimand and successful challenge, and News 9 carries the mother's account. The AI admission is reported through one district attorney's letter, not independently verified model output. The family and attorney remain unnamed. No broader custody consequence or disciplinary finding is inferred.

People described

The mother in the paternity and custody case (not named here), who told News 9 that the order denying a mental-evaluation request in her case cited cases that did not exist; and the attorney who requested a psychological evaluation of the child's father and was reprimanded in the order (not named here). Judge Wheeler, the AI user, is a named public official.

People reported harmed in this case

At least 2 people

0 AI participants · 2 other people harmed

Two people affected through the judge's use of ChatGPT: the mother, whose request for a psychological evaluation was denied by the order and who describes the discovery as alarming (News 9), and the attorney who requested the evaluation and was reprimanded in the order and challenged it at the Oklahoma Supreme Court (The Oklahoman). The child and the other parent are not counted because no harm to them is reported. The judge, the AI user, is not counted: he faces a possible disciplinary process but no sanction has been reported and the complaint bundled other allegations.

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

Tags

#justice#family-court#judge#fabricated-citations#chatgpt#oklahoma

Cite this case

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

APA

NOPE. (2026). Prosecutor: judge used ChatGPT citations in Oklahoma custody order later vacated. AI incidents. https://nope.net/incidents/2025-stephens-county-oklahoma-judge-chatgpt-fake-citations-paternity-order

BibTeX

@misc{2025_stephens_county_oklahoma_judge_chatgpt_fake_citations_paternity_order,
  title = {Prosecutor: judge used ChatGPT citations in Oklahoma custody order later vacated},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-stephens-county-oklahoma-judge-chatgpt-fake-citations-paternity-order}
}

Related cases

Medium ChatGPT

New Mexico Supreme Court fines attorney Stephen Aarons $5,000 and removes him from a murder appeal over ChatGPT-fabricated testimony

Santa Fe defense attorney Stephen Aarons used ChatGPT (OpenAI's o3) on a Rev.com transcript and the record to draft briefing in the murder appeal of Oscar Renee Sandoval; the brief contained fabricated witnesses and testimony (including police officers 'Michelle Amarillo' and 'Sanchez' and invented testimony attributed to real people) and misdescribed real precedents. After a 21 August 2026 show-cause hearing at which Aarons admitted he had not verified the output, the New Mexico Supreme Court's written order of 9 September 2026 held him in direct contempt, fined him $5,000 payable to the State Bar Client Protection Fund within 30 days, removed him from the case, barred him from appearing before the court pending a disciplinary-board referral, struck the filed briefs and reassigned the appeal to the public defender.

Medium ChatGPT

Colorado lawyer suspended for a year and a day, 90 days served, after filing a motion with fictitious ChatGPT case citations and blaming an intern

A Colorado lawyer who had recently moved into civil litigation used ChatGPT in April and May 2023 to find case law for a client's motion to set aside a judgment and cited three Colorado Court of Appeals decisions that did not exist, without reading or checking them. On the morning of the 5 May hearing he realised the cases were fabricated but did not tell the court or withdraw the motion, and when the judge raised concerns he falsely blamed a legal intern; six days later he filed an affidavit saying he had used ChatGPT. The judge denied the motion, said the denial did not rest on the invented cases, and ordered him to show cause why he should not be sanctioned and reported to attorney regulators. On 22 November 2023 Colorado's Presiding Disciplinary Judge approved a stipulation suspending him for one year and one day, with 90 days served and the rest stayed on two years' probation, for violating rules on competence, diligence, candour to the tribunal and honesty.

Medium GPT-5.4 and Claude Opus 5 (reported)

Massachusetts: fired teacher asks court to vacate an arbitration, saying the arbitrator improperly used AI tools to judge her AI-detector evidence

A kindergarten teacher at a public elementary school in Concord, Massachusetts, was dismissed in August 2025 after an unsatisfactory evaluation. In arbitration she argued that some of the principal's evaluations may have been produced with AI, relying on GPTZero estimates; the principal denied using AI beyond grammar checks. According to the arbitration decision as reported by The Concord Bridge, the arbitrator stated in an appendix that he used two AI tools, GPT-5.4 and Claude Opus 5, to research whether GPTZero was reliable, checked some of the sources they supplied, concluded that GPTZero's results deserved no weight, and upheld the dismissal on 27 August 2026. On 28 September 2026 the teacher asked Suffolk Superior Court to vacate the decision, alleging that the AI-assisted research was an improper investigation outside the hearing record that the parties were not told about or allowed to challenge. These are allegations in a complaint; the district declined to comment and no court has ruled.

Medium Unidentified AI tool

Ninth Circuit fines and suspends two immigration lawyers over briefs with AI-hallucinated citations and denials of AI use; immigration board follows

On 3 June 2026 the US Court of Appeals for the Ninth Circuit fined immigration attorneys Mike Singh Sethi and William Rounds $2,500 each and suspended both from practice before the court for six months. Briefs filed in an asylum petition for review cited two cases that do not exist and attributed quotations to opinions that do not contain them. In a motion to correct, the attorneys called the errors typographical, and at oral argument Rounds twice said AI was not used. In their response to the court's order to show cause, they conceded that the errors were probably the product of unauthorised AI use by the firm's unlicensed brief writers and a failure to check citations. The court said the suspension was owed to their repeated failure of candour. The Board of Immigration Appeals then suspended Sethi from practice before the Board, the immigration courts and the Department of Homeland Security for six months, effective 13 June 2026, and designated that decision as a precedent on 1 October 2026.

If you or someone you know is struggling, free and confidential support is available. Find a helpline near you at Signpost.

Back to all incidents