Lawyers hired by MD in Baltimore jail lawsuit reprimanded for AI-generated citations

An Alabama federal judge publicly reprimanded lawyers previously hired by the state of Maryland for citing fictitious cases determined to be “hallucinations” of the generative artificial intelligence program ChatGPT.

In a sanctions order filed Wednesday in the U.S. District Court for the Northern District of Alabama, Judge Anna Manasco disqualified Matthew Reeves and William Lunsford from further participation in a case in the court and referred the two lawyers to the Alabama State Bar and other licensing authorities, as first reported locally by The Baltimore Banner.

Maryland hired Reeves and Lunsford, both partners with Butler Snow LLP at the firm’s Huntsville office, in 2023 to defend state officials in a class-action lawsuit that challenged conditions at the Baltimore City Booking and Intake Center. The decades-long litigation brought by the jail’s detainees through the ACLU and Public Justice Center settled in 2016, with Maryland agreeing to bring its jail facilities into compliance and implement effective sanitation and housekeeping practices, among other items. The settlement agreement has since been extended multiple times.

According to the sanctions order, Reeves and Lunsford admitted that five citations in two motions they filed with the Alabama federal court were hallucinated by ChatGPT, which Reeves used in drafting the motions. Lunsford testified he did not make efforts to verify the contents of the motions, although his name also appeared on the motions’ filings. Both Reeves and Lunsford apologized to the court.

“Fabricating legal authority is serious misconduct that demands a serious sanction,” Manasco wrote. “In the court’s view, it demands substantially greater accountability than the reprimands and modest fines that have become common as courts confront this form of AI misuse.”

Reeves and Lunsford did not immediately return The Daily Record’s requests for comment, and a spokesperson for the Maryland Office of the Attorney General declined to comment.

Manasco wrote the citation of fake cases in a court filing — even where the lawyers who have cited AI hallucinations accept responsibility and apologize — cause a number of harms, including the opposing party wasting time and money to expose the “deception” and the client being deprived of arguments based on authentic judicial precedents.

According to the order, courts across the country have sanctioned attorneys for similar misuse of AI.

Earlier this year, a 4th Circuit panel questioned a Washington, D.C.-based lawyer during oral argument for citing multiple fictitious cases in briefs before the court. The lawyer, Eric Nwaubani, said he used different resources in preparing the briefs, but did not say whether he used AI when directly asked by the court. Nwaubani was not sanctioned in that case.