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Low reported severity Investigation Opened

Stephens County, Oklahoma: according to the district attorney, Judge Lawrence Wheeler told state investigators that a November 2025 order in a paternity and custody case, which denied a parent's request for a psychological evaluation and reprimanded that parent's attorney, cited at least two nonexistent cases produced by ChatGPT; the order was vacated after the attorney challenged it

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
Communicated with 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
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

A court order in a child custody case, which the judge has acknowledged to investigators contained at least two nonexistent ChatGPT-produced citations, denied a request for a psychological evaluation of the child's father and formally reprimanded the requesting attorney; the attorney had to seek relief from the Oklahoma Supreme Court before the order was vacated (per the district attorney's letter and The Oklahoman; the judge's attorney declined to comment).

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. According to the district attorney's 17 August 2026 letter, as reported by The Oklahoman, KFOR and News 9, the judge told the OSBI that he used ChatGPT for research and that at least two citations in his order, produced by ChatGPT, do not exist. ChatGPT communicated only with the judge; the mother and the reprimanded attorney were affected through the order he issued. The letter itself was not read.

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. 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. 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. 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. Applies to s3.

Hoodline rewrite of the Reuters report, read in full on 2026-09-29. Reuters relays the same district attorney letter. Applies to s4.

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

The order was issued in Stephens County District Court, Oklahoma, and challenged at the Oklahoma Supreme Court (The Oklahoman; KFOR). News 9 reports from Stephens County and describes the mother's case as handled there; her residence is not stated beyond that.

Reviewed for publication 2026-09-29: Published as a concrete case in which a judge's use of ChatGPT for research put nonexistent case citations into an order that denied a parent's request and reprimanded the requesting attorney in a child custody case. The ChatGPT admission rests on the district attorney's letter as relayed by several outlets, which was not read; the order and the Supreme Court filings were not read. The mother and the attorney are not named.

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). Stephens County, Oklahoma: according to the district attorney, Judge Lawrence Wheeler told state investigators that a November 2025 order in a paternity and custody case, which denied a parent's request for a psychological evaluation and reprimanded that parent's attorney, cited at least two nonexistent cases produced by ChatGPT; the order was vacated after the attorney challenged it. 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 = {Stephens County, Oklahoma: according to the district attorney, Judge Lawrence Wheeler told state investigators that a November 2025 order in a paternity and custody case, which denied a parent's request for a psychological evaluation and reprimanded that parent's attorney, cited at least two nonexistent cases produced by ChatGPT; the order was vacated after the attorney challenged it},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-stephens-county-oklahoma-judge-chatgpt-fake-citations-paternity-order}
}

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