New Mexico Supreme Court Fines Lawyer $5K for AI-Fabricated Witnesses
New Mexico Supreme Court fined a lawyer $5,000 for submitting AI-generated fake witnesses.
Why it matters: This case sets a precedent on the limits of AI use in legal practice and highlights the risks of relying on unverified AI-generated content in court filings, especially in criminal law.
- On Sept. 9, 2026, the New Mexico Supreme Court fined attorney Stephen Aarons $5,000 and held him in contempt.
- Aarons submitted a legal brief containing fabricated police testimony and fictitious witnesses generated by ChatGPT.
- Justice C. Shannon Bacon noted Aarons violated eight or nine provisions of the attorney code of conduct.
- The appeal was reassigned to public defender Kim Chavez Cook on Sept. 2, 2026.
On September 9, 2026, the New Mexico Supreme Court sanctioned defense attorney Stephen Aarons $5,000 and held him in contempt for submitting an appellate brief with fabricated police testimony and false witnesses created by OpenAI's ChatGPT. Aarons had used ChatGPT to summarize trial proceedings in the appeal of his client, Oscar Renee Sandoval, who was convicted of murder and sentenced to life in prison in 2025.
The court found that Aarons' filing included false testimony attributed to completely fictitious officers, such as Officer Michelle Amarillo and Officer Sanchez. Justice C. Shannon Bacon sharply criticized Aarons for failing to verify the accuracy of his court submission, noting that he violated at least eight or nine provisions of the code of conduct governing legal professionals.
Justice Bacon underscored the widespread awareness of AI hallucination risks, rhetorically asking, "Do you watch the news? Do you listen to the radio? Do you read anything about what's going on? Because the problem with lawyers relying on AI hallucinations is an ‘above-the-fold’ story every single day."
Despite Aarons' remorse and admission of an "honest mistake," the court referred him to the attorney disciplinary board for further investigation. The appeal was reassigned to public defender Kim Chavez Cook on September 2, 2026.
This case highlights the judicial system's growing scrutiny of AI use in legal practice. It reinforces that reliance on AI-generated material without human verification can undermine evidentiary standards and damage the integrity of criminal appeals.
By the numbers:
- $5,000 — Fine imposed on attorney Stephen Aarons
- 2025 — Year Oscar Renee Sandoval was convicted of murder and sentenced to life
- 8-9 — Code of conduct violations noted by Justice Bacon related to Aarons' conduct
Yes, but: Aarons claimed his use of ChatGPT was an honest mistake and expressed remorse, hoping the disciplinary board would consider this in their review.
What's next: The New Mexico attorney disciplinary board will now investigate Aarons' conduct further, with potential sanctions pending.