Butler Snow, a law firm long retained by the state of Alabama to defend its troubled prison system, is under judicial scrutiny after a lawyer used ChatGPT to generate fake case citations in a major civil rights case. U.S. District Judge Anna Manasco is now weighing possible sanctions—including fines, CLE requirements, and potential suspensions—after the firm filed multiple briefs that included fabricated legal authority.

The case involves Frankie Johnson, an incarcerated man who alleges he was stabbed approximately 20 times over 18 months at the William E. Donaldson prison near Birmingham. His 2021 lawsuit accuses prison officials of failing to protect him and ignoring widespread violence, corruption, and understaffing. The state hired Butler Snow to represent former corrections commissioner Jefferson Dunn in the case, as it has in other high-profile prison litigation.

At a hearing Wednesday, Judge Manasco expressed concern that recent AI-related sanctions have not deterred misuse. “If they were, we wouldn’t be here,” she said, calling the episode “proof positive” that current penalties may not go far enough. According to The Guardian, the citations at issue were created by attorney Matthew Reeves using ChatGPT to support routine procedural arguments, but were never independently verified.

Butler Snow has since acknowledged the error and issued apologies in court. Reeves admitted in a sworn statement that he failed to comply with the firm’s policy on AI use and did not cross-check the citations in Westlaw or PACER before filing. “I sincerely regret this lapse in diligence and judgment,” he wrote. “I take full responsibility.”

The firm’s lead attorney on the case, William Lunsford, told the court that Butler Snow is conducting a broader review of its filings and processes. “This is very fresh and raw,” Lunsford said. “The firm’s response to this is not complete yet.” Manasco gave the firm 10 days to submit a detailed plan for addressing the misconduct.

Johnson’s attorneys uncovered the fake cases in a May 7 filing related to a scheduling dispute. Butler Snow claimed legal precedent supported moving forward with a deposition, citing four fabricated decisions—including a “Kelley v. City of Birmingham” case that, in reality, only exists as a 1939 speeding ticket dispute. Johnson’s team later found another false citation in a prior filing.

Despite the lapse, the Alabama attorney general’s office signaled it would continue to use Butler Snow. “Mr. Lunsford remains the attorney general’s counsel of choice,” an AG representative confirmed at the hearing. Butler Snow also holds a multimillion-dollar contract to defend the state in other expansive lawsuits, including a DOJ-led case alleging Eighth Amendment violations in Alabama’s prisons.

Globally, legal scholars have now documented more than 100 cases involving “AI hallucinations” in court filings. Sanctions have so far ranged from minor penalties to suspensions, but the incident in Alabama may mark a turning point in judicial tolerance. “I’m seeing an acceleration,” said legal researcher Damien Charlotin, who tracks AI misconduct cases. “At some point, everyone will be on notice.”