Alabama Justices Toss Case Over ‘Egregious’ Attorney AI Misuse

The Alabama Supreme Court took the rare step of dismissing an appeal because of “grossly deficient” filings that relied on inaccurate citations spurred by AI hallucinations.

W. Perry Hall, a solo practitioner in Mobile, was ordered by the court to pay $17,200 in attorneys’ fees and costs. The justices also referred him to the Alabama State Bar for potential discipline and prohibited him from filing “anything else in this Court” unless another attorney in good standing with the Alabama State Bar signs the filing.

“The improper use of AI in the plaintiffs’ briefs was widespread and particularly egregious,” said the court Friday. The court and the opposing party, involved in a family dispute over a living trust, “have wasted a significant amount of time and resources reviewing and responding to the fabricated legal authorities,” the majority said.

Justice Greg Cook suggested in a special concurrence that dismissal of an appeal “is a particularly strong sanction that should be used sparingly, especially when there are other sanctions available.”

He said that while the particularly egregious nature of Hall’s conduct here compels a stronger result than a mere affirmance, sanctions for the misuse of AI should “generally be imposed against the lawyer rather than the client.”

The underlying case concerns a family dispute over Bruce Stewart’s alleged fiduciary duties as trustee of two living trusts. At issue is the appeal of the Mobile Circuit Court’s entry of summary judgment in favor of Bruce Stewart in a case brought by his niece and nephew, who were represented by Hall prior to his withdrawal.

Hall committed “egregious conduct” by filing briefs in the appeal that contain “an astounding number of invalid, inaccurate, and irrelevant citations to legal authorities,” the court said. His briefs contained “nonexistent or misquoted authorities,” and provided purported quotations from “‘an out-of-state case which does not appear to exist,” the court said.

Even though Hall declared in a reply brief that his mistakes “‘will not recur,’ the second and third citations after that declaration are to cases that do not exist,” the court said.

“The problem of fake citations in court filings is the result of attorneys failing to properly research and verify the results of AI-generated citations—in short, attorney negligence in checking his or her work,” the court said.

The case is Ibach v. Stewart, 2026 BL 149309, Ala., No. SC-2025-0106, 4/24/26.