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A Lawyer Filed Witnesses That Do Not Exist
The New Mexico Supreme Court has fined Santa Fe defense attorney Stephen Aarons $5,000, held him in contempt and referred him to the state's attorney disciplinary board, after his brief in a murder appeal quoted testimony from witnesses who do not exist.
Aarons said he fed trial transcripts into ChatGPT expecting a summary of the proceedings, and that he did not understand the degree to which AI could hallucinate facts. He called it an honest mistake.
From the bench, Justice C. Shannon Bacon asked him: "Do you watch the news? Do you listen to the radio?" — noting that these stories appear every single day.
They do. The AI Hallucination Cases database listed 2,039 court decisions involving hallucinated material as of 12 September 2026, and dozens of lawyers have been sanctioned for fabricated case citations.
What makes this one different is what was fabricated. Most of those cases are invented case law. This was invented evidence, in a case about a killing.
Sandoval's conviction stands and nothing here bears on his guilt. The sanction is against his former lawyer. All footage is licensed stock; nothing on screen depicts the case.
The spine
The New Mexico Supreme Court fined Santa Fe defense attorney Stephen Aarons $5,000, held him in contempt, and referred him to the state's attorney disciplinary board, after his brief in a murder appeal contained testimony from witnesses who do not exist. He had run trial materials through ChatGPT.
The order
- Court: New Mexico Supreme Court. Order issued Wednesday (reported 11 Sep 2026). Oral argument had been heard 21 August 2026.
- The filing "contained false testimony from wholly fabricated witnesses", including the fictional detail that "the shooter was wearing dark pants and a white shirt."
- The court found Aarons "demonstrated a lack of remorse and a lack of concern for his client."
- Sanction: $5,000, contempt, referral to the disciplinary board; briefs stricken; Aarons removed from the appeal.
The client
- Oscar Renee Sandoval, convicted of the murder of the mother of his children; sentenced to life in prison.
- The appeal is still pending and was reassigned (2 September 2026) to public defender Kim Chavez Cook.
How this was verified — the rest of the fact sheet
The scale
- AI Hallucination Cases database (Damien Charlotin) — 2,039 cases identified, page last updated 12 September 2026.
- Dozens of lawyers have been sanctioned for fabricated case citations. What is unusual here is that the fabrication was evidence, not case law.
Sources
- Reuters (syndicated via GV Wire, Detroit News, Khaleej Times), 11 Sep 2026.
- Al Jazeera, "US lawyer cites fake witnesses in murder case, blames ChatGPT", 11 Sep 2026.
- Ars Technica, 11 Sep 2026. · The Verge, 11 Sep 2026.
- damiencharlotin.com/hallucinations (count read 12 Sep 2026).
References
Reporting drawn from Reuters · Al Jazeera · Ars Technica · The Verge · damiencharlotin.com/hallucinations
What the reel says
Narration as scripted and voiced.
A defense lawyer filed testimony from witnesses who do not exist. It was an appeal against a murder conviction, and the witnesses came out of a chatbot
The New Mexico Supreme Court fined Stephen Aarons $5,000 on Wednesday, held him in contempt, and referred him to the state disciplinary board
The court said his brief contained false testimony from wholly fabricated witnesses. One invented line had the shooter wearing dark pants and a white shirt. None of it was in the record
His client is Oscar Renee Sandoval, convicted of murder and serving life. Aarons was appealing that conviction. The appeal has now been handed to a public defender
Aarons told the court he had fed the trial transcripts into ChatGPT expecting a summary. He said he did not understand how far artificial intelligence can hallucinate, and he called it an honest mistake
Justice C. Shannon Bacon put a question to him from the bench. "Do you watch the news? Do you listen to the radio?" She said these stories appear every single day
They do. A public database of court decisions involving hallucinated material listed 2,039 cases as of today. Dozens of lawyers have already been sanctioned for inventing case law
What makes this one different is what was faked. Most of these cases are invented citations. This was invented evidence in a case about a killing
The briefs have been struck and the appeal begins again. A man serving life for murder will have his case argued a second time because the first attempt was written with a machine
