{"meta":{"exportedAt":"2026-10-15T07:07:07.881Z","formatVersion":2,"selection":{"q":"prison-litigation","system":"","harm":"","context":"","country":"","role":"","relation":"core","evidence":"","year":"2025","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":1,"coverage":{"cases":1,"countries":0,"languages":1,"unknownLocation":1,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":1,"minors":0,"coreRelations":1,"contextualRelations":0,"mixedRelations":0,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2025-alabama-federal-court-disqualifies-three-butler-snow-lawyers-over-chatgpt-fabricated-citations","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'On May 7, 2025, Defendant Dunn filed a motion for leave to take the'; 'Then, at 4:21 p.m. on May 12, 2025, Defendant'; 'In total, there were five problematic citations across two motions'","relation":"supports","source_id":"s1"},{"locator":"'filed two motions with five'","relation":"supports","source_id":"s3"}],"assertion":"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."},{"id":"c2","status":"documented","evidence":[{"locator":"'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'","relation":"supports","source_id":"s1"},{"locator":"'the court has conducted independent searches for each allegedly fabricated citation, to no avail'","relation":"supports","source_id":"s2"}],"assertion":"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."},{"id":"c3","status":"documented","evidence":[{"locator":"'In short, attorney Matt Reeves used ChatGPT to obtain'; 'case citations returned by ChatGPT through independent review in Westlaw or'","relation":"supports","source_id":"s1"},{"locator":"'failed to verify the case citations returned by ChatGPT through independent review in Westlaw or Pacer before including them'","relation":"supports","source_id":"s2"}],"assertion":"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."},{"id":"c4","status":"documented","evidence":[{"locator":"'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'","relation":"supports","source_id":"s1"},{"locator":"'Manasco also publicly reprimanded the lawyers; referred them to the Alabama State Bar'","relation":"supports","source_id":"s3"}],"assertion":"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."},{"id":"c5","status":"documented","evidence":[{"locator":"'reviewed more than 2,400 separate legal'; 'citations across 330 filings.”'; 'revealed no additional “legal citations that were fabricated,”'","relation":"supports","source_id":"s1"},{"locator":"'No other instances of incorrect case references were found.'","relation":"supports","source_id":"s3"}],"assertion":"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."},{"id":"c6","status":"reported","evidence":[{"locator":"'and in these two instances I did not comply with policy'; 'I would hope your honor would not punish my colleagues'","relation":"supports","source_id":"s2"}],"assertion":"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."},{"id":"c7","status":"documented","evidence":[{"locator":"'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'","relation":"supports","source_id":"s1"}],"assertion":"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."}],"effects":[{"label":"three lawyers were publicly reprimanded, disqualified and referred to the state bar over ChatGPT-fabricated citations","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://storage.courtlistener.com/recap/gov.uscourts.alnd.179677/gov.uscourts.alnd.179677.204.0.pdf","kind":"court_record","access":"read","language":"en","translation_note":"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.","independence_group":"johnson-v-dunn-nd-ala-sanctions-order"},{"id":"s2","url":"https://www.theguardian.com/us-news/2025/may/24/alabama-prison-lawyers-chatgpt-butler-snow","kind":"news_report","access":"read","language":"en","translation_note":"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.","independence_group":"guardian-butler-snow-may-2025"},{"id":"s3","url":"https://www.abajournal.com/news/article/5-fabricated-cases-lead-federal-judge-to-kick-3-butler-snow-lawyers-off-case","kind":"news_report","access":"read","language":"en","translation_note":"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.","independence_group":"johnson-v-dunn-nd-ala-sanctions-order"}],"version":1,"ai_roles":["own_use","others_use"],"contexts":["justice","work"],"unknowns":["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."],"geography":{"basis":"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.","court_countries":["US"],"event_countries":[],"affected_person_countries":[]},"publication":{"basis":"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.","reviewed_on":"2026-10-15"},"ai_involvement":{"basis":"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.","status":"supported"},"person_relations":["communicated_with"]},"name":"Alabama federal judge reprimands and disqualifies three Butler Snow lawyers and refers them to the state bar over ChatGPT-fabricated citations (2025)","summary":"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.","incidentDate":"2025-05-07","incidentEndDate":"2025-07-23","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2025-05-24","aiSystem":"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","aiProduct":"ChatGPT","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm","legal_harm"],"harmOutcomeSummary":"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.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":2,"affectedCountStatus":"exact","affectedCountEvidence":"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.","victimAgeRange":"adult","jurisdiction":"US","platformType":"assistant","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://storage.courtlistener.com/recap/gov.uscourts.alnd.179677/gov.uscourts.alnd.179677.204.0.pdf","primarySourceLabel":"US District Court for the Northern District of Alabama, Johnson v. Dunn, No. 2:21-cv-01701, Sanctions Order (Doc. 204), 23 July 2025","firstPublishedAt":"2026-10-15T03:01:17.679643+00:00","updatedAt":"2026-10-15T03:01:17.679643+00:00","scopeVersion":"facts-v3","tags":["alabama","federal-court","prison-litigation","lawyers","fabricated-citations","chatgpt","disqualification","bar-referral"]}]}