Georgia · state supreme court · 2026

Payne v. State

Supreme Court of Georgia, 5 May 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Ga.

  1. Court. Supreme Court of GeorgiaCOURT
  2. Level. state supreme courtLEVEL
  3. Date. 5 May 2026DATED
  4. Docket. No. S26A0459DOCKET
  5. Documents. one document, 6 passages quoted belowON FILE
  6. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 5 May 2026 · source · PDF · 8 pages

Hannah Payne was sentenced to life in prison plus 13 years for the murder and false imprisonment of Kenneth Herring and the possession of a firearm during the commission of a felony. In response to Payne’s motion for new trial, the assistant district at- torney assigned to the case, Deborah Leslie, filed a brief that con- tained non-existent cases and cases that do not stand for the prop- osition asserted in the brief. In an order largely prepared by ADA Leslie, the trial court denied Payn e’s motion for new trial.

In an order largely prepared by ADA Leslie, the trial court denied Payn e’s motion for new trial. That order contained citations to non-existent cases and cases that do not stand for the proposition asserted in the order. In response to Payne’s appeal, ADA Leslie once again cited cases that do not stand for the proposition asserted.

On March 20, 2026, after oral argument in this case, this Court entered an order directing counsel for the State to file a supplemental brief explaining, among other things, how the Sep- tember 12, 2025 order of the trial court denying Payne’s motion for new trial (which reflects that ADA Leslie prepared that order) came to include nine case citations that either do not exist or do not stand for the propositions for which they are cited.

ADA Leslie acknowledged that the case citations generated by artificial intel- ligence software were not independently verified before inclusion in the State’s briefs or proposed order and represented that she had implemented safeguards to ensure that fictitious or misattributed authorities would not appear in any future filings.

These filings, as well as the trial court’s order, contain multiple case citations which either do not exist, or which exist but do not support the propositions of law for which they are cited.

4 4. Because the trial court’s September 12, 2025, order deny- ing Payne’s motion for new trial contains numerous fictitious or misattributed case citations, we hereby vacate the trial court’s or- der and remand the case to the trial court with instructions that it prepare and issue a new order on Payne’s motion for new trial. The trial court’s order shall not contain any fictitious or misattributed case citations, and given the unfortunate circum- stances that have led us to this point, the trial court’s order shall not be prepared by counsel for either party.

What the text mentions

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Where this fits

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More from Supreme Court of Georgia, from Georgia, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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