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The court found fictional witnesses and fabricated police testimony in a murder appeal, underscoring that a generated summary cannot substitute for checking the record.
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A New Mexico Supreme Court contempt ruling underscores that AI-assisted legal drafting remains subject to ordinary professional verification duties. Attorney Stephen Aarons submitted a murder-appeal brief containing invented witnesses and unsupported police testimony after asking ChatGPT to summarize case materials. The court imposed a $5,000 fine and referred him for disciplinary review; Oscar Renee Sandoval’s life-sentence appeal continues separately.
The fabricated material included claims about a shooter’s clothing, not merely an inaccurate citation or paraphrase.
Aarons said he supplied ChatGPT with a computer-generated transcript and other case materials seeking a “bulletproof summary.”
The court found Aarons failed to verify the filing before submitting it in a criminal case.
The New Mexico Supreme Court has fined attorney Stephen Aarons $5,000 and held him in contempt after finding fabricated police testimony and fictional witnesses in a murder-appeal brief prepared with ChatGPT assistance. The court will also refer him for a disciplinary investigation.
The sanction concerns the appeal of Oscar Renee Sandoval, who was convicted of murder and sentenced to life in prison. That appeal remains pending. The court said Aarons’s primary brief contained false testimony from wholly fabricated witnesses, putting invented material into a filing in a criminal case.
Aarons told the court that he fed ChatGPT a computer-generated transcript and other case materials. He said he expected what he called a “bulletproof summary” while preparing the appeal. But the court found the submitted brief included material that had no basis in the record.
The distinction is straightforward but consequential: supplying source material to a chatbot does not ensure that its prose remains tied to that material. Aarons was held in contempt for failing to verify the filing’s accuracy before it reached the court.
The court said the filing appeared to include fictional statements that the shooter wore dark pants and a white shirt. Alongside the finding of fabricated witnesses, that detail makes this more than a dispute over an imprecise legal citation or paraphrase.
Aarons said he had not understood the degree to which AI could hallucinate facts. He characterized the episode as an honest mistake and said he was remorseful, while hoping the disciplinary board would take that explanation into account.
The unresolved professional question now moves to the disciplinary process. For Sandoval’s case, the immediate reality is separate: his life-sentence appeal is still active, even though the lawyer who submitted its primary brief has been sanctioned over its accuracy.
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The New Mexico Supreme Court held defense lawyer Stephen Aarons in direct contempt after he filed a ChatGPT-generated appellate brief containing fabricated witness testimony and inaccurate descriptions of legal precedents. The court fined him $5,000, barred him from appearing before the court pending disciplinary proceedings, struck the briefs, and ordered a new lawyer for his client.
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