
Inset: Hannah Payne during her sentencing proceeding connected Dec. 15, 2023 (Law&Crime). Background: Clayton County Assistant District Attorney Deborah Leslie addresses the Supreme Court of Georgia (Supreme Court of Georgia).
It's punishment clip for a Georgia authoritative who repeatedly filed documents containing AI-generated citations that either referenced the incorrect cases oregon referenced wholly fictitious cases.
The ineligible filings astatine contented came successful the people of an entreaty lodged by a pistillate convicted of murdering a antheral successful a citizen's apprehension gone wrong.
In December 2023, Hannah Payne, 25, was convicted connected 2 counts of felony murder, 3 counts of possession of a limb during a crime, and 1 number each of malice murder, aggravated assault, and mendacious imprisonment implicit the May 2019 decease of Kenneth Herring, 62.
Payne was subsequently sentenced to beingness successful prison with the anticipation of parole aft serving astatine slightest 43 years down bars.
Payne appealed her condemnation and sentence, citing ineffective assistance of counsel. After losing her question for a caller proceedings successful precocious summertime 2025, the entreaty went to the Supreme Court of Georgia this March. The court's members noted the deficient filings during oral statement and directed the authorities to explicate itself.
Those explanations came by mode of "a supplemental little and affidavit successful which" Clayton County Assistant District Attorney (ADA) Deborah Leslie "acknowledged utilizing artificial quality bundle to draft" the state's reply briefs arsenic good arsenic the eventual bid the territory tribunal itself utilized to contradict Payne's question for a caller trial, the precocious tribunal noted successful an eight-page opinion imposing sanctions.
In the precocious court's terms, the AI bundle initially resulted successful "a little that contained non-existent cases and cases that bash not basal for the proposition asserted successful the brief." Then the mistakes compounded.
"In an bid mostly prepared by ADA Leslie, the proceedings tribunal denied Payne's question for caller trial," the sentiment explains. "That bid contained citations to non-existent cases and cases that bash not basal for the proposition asserted successful the order. In effect to Payne's appeal, ADA Leslie erstwhile again cited cases that bash not basal for the proposition asserted."
On apical of the mea culpas, the authoritative was hesitant to admit responsibility erstwhile quizzed by the justices astir the bid she prepared for the proceedings court, a footnote successful the sentiment recalls.
"No, your honor, I bash not judge so, they were not. I did hole an order," Leslie said successful effect to a question. "That bid was revised."
But the grounds was incontrovertible.
"When this Court pointed retired that these aforesaid cases were cited successful the State's briefing opposing Payne's question for caller trial, ADA Leslie offered to supply this Court with supplemental briefing connected this issue," the sentiment goes on.
In its archetypal bid aft oral argument, the precocious tribunal directed Leslie to instrumentality banal of "nine lawsuit citations that either bash not beryllium oregon bash not basal for the propositions for which they are cited."
This fig turned retired to beryllium an undercount.
The sentiment explains the voluble mistakes astatine length:
In summation to the 9 cases listed successful this Court's March 20, 2025, order, ADA Leslie identified 12 further cases successful her briefing earlier the proceedings tribunal that she acknowledges were generated by artificial quality software, were not independently verified, and bash not basal for the propositions for which they were offered. ADA Leslie besides withdrew reliance connected 9 authorities cited successful the State's December 16, 2025, appellate little earlier this Court which she stated "were cited for propositions not supported by the existent holdings of those decisions; lawsuit citations that bash not correspond to existing Georgia oregon national precedent; and/or lawsuit quotations that bash not accurately bespeak the connection of the cited opinions[.]"
And for that level of mistaken citation, Justice Benjamin A. Land had peculiarly harsh words for some Leslie and her office.
"These filings, arsenic good arsenic the proceedings court's order, incorporate aggregate lawsuit citations which either bash not exist, oregon which beryllium but bash not enactment the propositions of instrumentality for which they are cited," the sentiment continues. "While we person nary regularisation against the liable usage of artificial quality bundle by attorneys, citing cases that bash not beryllium oregon bash not enactment the proposition for which they are cited is simply a usurpation of this Court's rules and falls acold beneath the behaviour we expect from Georgia lawyers."
To that end, Leslie and the Clayton County District Attorney's Office were formally admonished – though this nationalist censure does not use to the territory lawyer individually.
Additionally, Leslie herself is suspended from practicing earlier the Georgia Supreme Court for six months. To beryllium reinstated, she indispensable implicit 12 hours of further continuing ineligible acquisition that focuses connected "the due usage of artificial quality bundle successful the ineligible system."
"Given the important fig of wholly inaccurate lawsuit citations recovered successful these filings, and the information that counsel for the State did not independently verify the accuracy of these citations, the substance poses a superior interest for america and for the integrity of these proceedings and calls for america to workout our inherent authorization to power these proceedings successful the furtherance of justice, arsenic good arsenic the authorization granted to america by Supreme Court Rule 7 to authorisation attorneys who interruption our rules," Land explains.
As for Payne's ain case, the erstwhile bid denying her question for a caller proceedings has been vacated and remanded. Now, the proceedings tribunal indispensable hole and contented its ain bid connected the matter. And, to somewhat belabor the point, the caller bid "shall not incorporate immoderate fictitious oregon misattributed lawsuit citations" and "shall not beryllium prepared by counsel for either party."
Finally, the tribunal granted a question to clarify filed by Payne, directing the authorities to nutrient find of immoderate communications with the proceedings tribunal astir the since-shelved bid denying the caller proceedings motion. In the lawsuit specified communications exist, those documents indispensable beryllium provided to the precocious tribunal and Payne's attorneys "without delay."

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