A federal court has put a civil case on hold as a punishment for meritless filings by lawyers on both sides. Attorneys for the plaintiff and the defendant had both independently used AI to draft and research filings that relied on AI-generated hallucinations as legal authorities. District Judge Sharion Aycock disqualified all four attorneys involved from participating in the case and imposed further sanctions, including fines and a two-year ban from the district court.
Although the across-the-board AI mishaps have caught the eye of legal writers, they are not unique to this case. Even in high-stakes cases with experienced attorneys, state and federal courts are encountering cites to hallucinated cases and other AI-driven errors in court filings.
A Contract Dispute and a Messy Beginning
Withers v. City of Aberdeen stems from Attorney Tom Withers III’s claim against a Mississippi city over unpaid bills for his work. Kathleen M. Wilson, a Baton Rouge attorney, filed the lawsuit in the Middle District of Louisiana in 2023. Since Aberdeen is in the Northern District of Mississippi, the Louisiana court transferred the case to that district. As Wilson has no Mississippi law license, she moved for admission pro hac vice (for this matter only).
These admission motions are routine in federal courts, but in Withers, they would eventually become part of the issues. A resident attorney had to sign Wilson’s motion and act as local counsel; here, Shauncey Hunter Ridgeway of Christian & Small LLP sponsored Wilson. The City of Aberdeen had also retained an out-of-state attorney, Kathryn Y. Williams, and local counsel Mark C. McClinton signed her motion to appear pro hac vice.
In late 2025, the City filed for summary judgment, together with a challenge to an accounting. Withers then filed a response to the City’s motion. According to the court, these three documents contained AI hallucinations: case citations that did not exist. All four lawyers had signed the court filings, resident attorneys and non-resident attorneys alike.
After learning of this, Judge Aycock issued an order to show cause. She scheduled a hearing in January 2026 for all four lawyers, ordering them to give her a reason why the court should not sanction them for providing false information.
First Drafts and the Basis for Sanctions
Any attorney who signs a federal court filing is vouching for it under Rule 11 of the Federal Rules of Civil Procedure. According to Rule 11, a signing attorney certifies that the filing’s “claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for … establishing new law.” If a filing fails to meet Rule 11’s standards, the court can impose sanctions on the attorney and their law firm.
The non-resident attorneys, Williams and Wilson, had produced these filings. Both admitted at the hearing that they had used artificial intelligence and failed to check the legal authorities that appeared in the documents. For her part, Williams had used an AI research tool not designed for Mississippi law, and Wilson had created her filings with First Drafts, a legal composition software. (In an email to the New York Times, the software company emphasized that it had warned users that its work “must be independently verified.”)
By acting as resident attorneys for the lawyers admitted pro hac vice, McClinton and Ridgeway assumed a duty to be “responsible for the conduct of the proceeding before the court,” according to Local Uniform Civil Rule 83.1(d)(3). But neither of the resident attorneys had reviewed the filings by their co-counsels before agreeing to sign them, leaving them open to sanctions as well.
All four attorneys were disqualified from the case, leaving their clients without counsel. The court handed down the harshest penalties to Attorneys Wilson and Williams, banning them from admission to the Northern District of Mississippi for two years. As it happened, Wilson had also made erroneous AI filings in a Louisiana court, even after this incident; the court ordered her to complete a CLE course on AI usage. Wilson and Williams received fines of $2,500 and $3,500, while the resident attorneys were fined $1,000 each.
Attorneys and the Ethics of AI Use
This is not nearly the first case of sanctions against attorneys for using AI hallucinations in a federal court case. That was in 2023, in Mata v. Avianca, an injury case against an airline, just months after ChatGPT's release in late 2022. As lawyers and the public have increased their reliance on AI, state and federal courts have faced case after case of attorneys allowing unchecked errors into filings.
Although each state bar has its own Rules of Professional Conduct, each one mostly mirrors the ABA’s Model Rules. The Rules of Professional Conduct require competence in practice, honesty to the court, and taking responsibility for subordinate lawyers. These are only three of the standards that a lawyer could potentially violate through unchecked AI use.
Some courts have responded by restricting generative AI usage, while others require disclosure or urge caution. But as long as workloads provide an incentive to generate filings at a moment’s notice, AI drafting and research will persist. A focus on foundational research practice can help attorneys produce responsibly drafted work with AI research tools.
