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Alabama Supreme Court dismisses two siblings' family-trust appeal as a sanction after their lawyer admits using AI that produced fake citations

On 24 April 2026 the Supreme Court of Alabama dismissed an appeal by two siblings in a family dispute over living trusts because their lawyer, W. Perry Hall, had filed briefs in which most of the legal authorities were misquoted or did not exist. The court said they appeared to be AI hallucinations, and at a show-cause hearing in February 2026 Hall admitted that many authorities did not exist and that he had improperly used AI to obtain them. The court ordered Hall to pay the opposing party's fees and costs of $17,200 and double appeal costs, barred him from filing in the court without a co-signing attorney and referred him to the Alabama State Bar. It said the dismissal was imposed as a sanction because of the particularly egregious facts. One justice, concurring in part and dissenting in part, objected to dismissing the appeal as a sanction for the lawyer's conduct but would have affirmed the judgment against the clients on the merits.

AI system
Unidentified AI research tool
Occurred
24 Apr 2026
Reported
24 April 2026
Event location
United States
What the AI did
Communicated with the person · Informed a human decision about the person
Reported harm
Legal HarmProfessional HarmFinancial Loss
Whose AI use
Their own AI use · Someone else’s AI use
Setting
Justice · Work · Relationships
Evidence
AI involvement supported · Causal attribution established · 1 source
6 claims: 6 documented. 3 open questions
People reported harmed
3 people

AI system as recorded: An AI research tool that, according to the lawyer's reply-brief footnote quoted by the court, summarised legal commentary and misattributed quotations; the lawyer admitted using AI to obtain authorities that do not exist. No product is named in the opinion

What Happened

The appeal. Two siblings appealed a Mobile Circuit Court summary judgment for a relative in a dispute over the relative's duties as trustee of family living trusts. Their appellate lawyer filed an opening brief and a reply brief that, the Supreme Court of Alabama found, cited numerous invalid, inaccurate or irrelevant authorities; most were misquoted or nonexistent. The appellee's brief pointed out the problem. The reply brief added further fabricated authorities and addressed the issue only in a footnote, which said that an AI research tool had misattributed quotations from two secondary sources.

The admission. The court ordered the lawyer to show cause why he should not be sanctioned. At the hearing on 4 February 2026 he admitted that many of the authorities in his briefs did not exist and that he had improperly used AI to obtain them, accepted responsibility, said he had self-reported to the state bar and paid the appellee's estimated fees and costs of $17,200.

The decision. The court held that briefs built on fabricated authorities left it nothing to review, dismissed the appeal, and said in a footnote that the dismissal was imposed as a sanction because of the particularly egregious facts. It also sanctioned the lawyer and referred him to the bar. One justice, concurring in part and dissenting in part, wrote that dismissal was not appropriate as a sanction for a lawyer's conduct but would have affirmed the trial court's judgment on the merits. Another justice concurred in the dismissal and wrote that the lawyer's representation on appeal had been of no benefit to his clients.

Reported harm

According to the Supreme Court of Alabama, the siblings' appeal was dismissed as a sanction because their lawyer's briefs relied on authorities that were misquoted or did not exist, which he admitted he had obtained by improperly using AI; the lawyer was ordered to pay $17,200 in fees and costs plus double appeal costs and was referred to the state bar.

Outcome

Resolved

Supreme Court of Alabama, SC-2025-0106, opinion released 24 April 2026: appeal dismissed; the appellants' motion to file supplemental briefs denied; the lawyer ordered to pay the appellee's attorney fees and costs of $17,200 (he had already delivered a check for that amount on 9 February 2026) and double costs of the appeal, prohibited from filing in the court unless another attorney in good standing signs, and referred to the Alabama State Bar for potential discipline (he had also self-reported); his motion to withdraw granted. A justice concurring in part and dissenting in part disagreed that dismissal was an appropriate sanction for a lawyer's conduct and would instead have affirmed the trial court's judgment on the merits; a second justice concurred in the dismissal but disagreed with parts of the sanctions against the lawyer. The outcome of any bar proceeding is not reported in the inspected source.

What remains unknown

  • Which AI tool the lawyer used; the opinion names none.
  • Whether the dismissal changed the clients' substantive position; the trial court's summary judgment stands, the main opinion does not decide the merits, and one justice would have affirmed the judgment.
  • The outcome of the Alabama State Bar referral.

What the evidence supports

AI involvement: supported. The court found the briefs' authorities appeared to be AI hallucinations, the lawyer admitted at the show-cause hearing that he had improperly used AI to obtain authorities that do not exist, and his reply-brief footnote quoted by the court says an AI research tool misattributed quotations. The AI output reached the court through the briefs, and the court dismissed the clients' appeal because those briefs rested on fabricated authorities (informed_decision_about for the clients); the lawyer received the fabricated output from the tool (communicated_with) and was sanctioned.

6 claims: 6 documented. What the statuses mean

Documented The appellants' lawyer filed briefs whose citations the court found numerous, invalid, inaccurate or irrelevant, most of them misquoted or nonexistent, and which the court said appear to be AI hallucinations.

Causal attribution. The court's own findings.

  • publicportal-api.alappeals.gov(opens in new tab) supports · English
    'filed briefs in this appeal that contain numerous invalid, inaccurate, and/or irrelevant citations to legal authorities'; 'They appear to be artificial-intelligence ("AI") "hallucinations," i.e., fake authorities created by an AI system'; 'Most of the legal authorities in the briefs are misquoted or nonexistent'
Documented In a reply-brief footnote quoted by the court, the lawyer attributed two misquotations to an AI research tool that summarised commentary.

Causal attribution. The lawyer's statement as quoted in the opinion.

Documented At the 4 February 2026 show-cause hearing the lawyer admitted that many authorities in his briefs did not exist and that he had improperly used AI to obtain them, and said he had self-reported to the Alabama State Bar.

Causal attribution. The court's record of the hearing.

  • publicportal-api.alappeals.gov(opens in new tab) supports · English
    'Hall admitted that many of the legal authorities in his briefs do not exist and that he improperly used AI to obtain those authorities'; 'Hall also informed the Court that he had self-reported his actions to the Alabama State Bar'
Documented The court dismissed the appeal because the briefs were grossly deficient, and said the dismissal was imposed as a sanction because of the particularly egregious facts.

Causal attribution. Established by the opinion.

  • publicportal-api.alappeals.gov(opens in new tab) supports · English
    'Because those briefs are grossly deficient under the Alabama Rules of Appellate Procedure, we dismiss the appeal'; 'the dismissal of this appeal is imposed as a sanction because of the particularly egregious facts before us'
Documented The court ordered the lawyer to pay $17,200 in attorney fees and costs and double costs of the appeal, and referred him to the Alabama State Bar for potential discipline.

Causal attribution. Established by the opinion.

  • publicportal-api.alappeals.gov(opens in new tab) supports · English
    'Hall is hereby ordered to pay attorney fees and costs'; 'in the amount of $17,200'; 'Hall is ordered to pay double costs'; 'We also refer Hall to the Alabama State Bar for potential discipline'
Documented Justice Sellers, concurring in part and dissenting in part, disagreed that dismissal was an appropriate sanction for a lawyer's conduct but would have affirmed the trial court's judgment on the merits; Justice Mendheim, who concurred in the dismissal, wrote that the lawyer's representation on appeal was of no benefit to the clients.

Causal attribution. Two separate opinions in the same record; neither is the court's holding.

  • publicportal-api.alappeals.gov(opens in new tab) supports · English
    'SELLERS, Justice (concurring in part and dissenting in part)'; 'I do not agree that dismissal of the appeal is appropriate as a sanction for the conduct of a lawyer'; 'I would affirm the judgment of the Mobile Circuit'; 'MENDHEIM, Justice (concurring in part and dissenting in part)'; 'I concur in the dismissal of this appeal'; 'His representation on appeal was of no benefit to them'

Sources

1 source inspected. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in full in English by the research agent (an AI) on 2026-10-14 from CourtListener's archived copy of this court PDF (storage.courtlistener.com, HTTP 200, text extracted with pdftotext) because the court portal URL returned HTTP 403 to the agent; no translation was needed. Applies to s1.

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

The appeal was decided by the Supreme Court of Alabama on appeal from the Mobile Circuit Court. The appellants' residence is not used.

Reviewed for publication 2026-10-14: Published because the Supreme Court of Alabama's opinion establishes that it dismissed two appellants' appeal as a sanction after their lawyer filed briefs built on fabricated authorities that he admitted he had obtained by improperly using AI, and that it sanctioned the lawyer and referred him to the state bar. The opinion was read in full.

People described

Two adult siblings who were appealing a summary judgment against them in a dispute with a relative over family living trusts, whose appeal was dismissed; and their appellate lawyer, who was sanctioned and referred to the state bar. The siblings are private people and are not named here.

People reported harmed in this case

3 people

1 AI participant · 2 other people harmed

One AI user: the appellate lawyer, sanctioned and referred to the bar. Two other people: the two appellants whose appeal was dismissed. The appellee, whose fees were reimbursed, is not counted.

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

Cite this case

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

APA

NOPE. (2026). Alabama Supreme Court dismisses two siblings' family-trust appeal as a sanction after their lawyer admits using AI that produced fake citations. AI incidents. https://nope.net/incidents/2026-alabama-supreme-court-dismisses-family-trust-appeal-over-lawyer-ai-hallucinated-citations

BibTeX

@misc{2026_alabama_supreme_court_dismisses_family_trust_appeal_over_lawyer_ai_hallucinated_citations,
  title = {Alabama Supreme Court dismisses two siblings' family-trust appeal as a sanction after their lawyer admits using AI that produced fake citations},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2026-alabama-supreme-court-dismisses-family-trust-appeal-over-lawyer-ai-hallucinated-citations}
}

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