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.
Docket entry 653, 10 October 2025 · source · PDF · 18 pages
Docket text. MEMORANDUM OPINION & ORDER as to Glennie Antonio McGee re: sanctions as to Attorney James A. Johnson. Signed by District Judge Terry F. Moorer on 10/10/25. (tot) (Entered: 10/10/2025)
It is determined that Attorney James A. Johnson utilized an artificial intelligence (“AI”) program in the drafting of a motion which as a result contained fabricated citations that he failed to check prior to submitting the motion to the Court. The issue was discovered by opposing counsel, confirmed by the Court, and acknowledged by Mr.
1 In its response in opposition (Doc. 532, filed 7/10/25), the United States indicates that counsel for Defendant McGee appears to have fabricated citations in that he cites “several nonexistent cases, attributing false quotations to others, and directing this Court to precedent that the Supreme Court reversed more than 40 years ago. McGee’s incorrect and outright fake citations—many of which the United States has been unable to locate despite diligent searches —bear the hallmarks of legal authorities ‘hallucinated’ by artificial intelligence.” Doc.
532 at 1. In its opposition, the United States describes at length the basis for his belief that counsel for Defendant McGee fabricated citations. Id. at 5-8.
In the light of the seriousness of the accusation, the Court conducted independent searches related to the citations at issue. Regarding the cases that allegedly do not exist, the Court’s search revealed the same problems and the allegations made by the United States were correct: the cases do not exist , citations did not go to the referenced names , and/or the cases did not relate to the issues at hand. For the cases that relate to misrepresentations or false quotations, the search did not fare any better for defending the use of those citations in the manner and context given.
As part of the response, Mr. Johnson was ordered to append to his filing copies of each allegedly fabricated legal authority or if he could not provide such copies, to submit a sworn declaration that provides a thorough explanation for how the motion and allegedly fabricated cases were generated. Id.
545. The response asserts the use of fictitious authorities was a n embarrassing mistake, but that Mr. Johnson did not knowingly or intentionally use a resource that he thought would or could make up the citations.
Id. at 5-6. He further asserts that after additional research he now understands that many paid and free AI programs can create citations that do not exist and are unreliable. He states “[w]hen I used Ghostwriter the idea that the search results, which looked authentic, could be completely made up never even entered my mind.
This concept is well known and is a longstanding principle in the practice of law. Yet, t he improper use of generative AI is a problem that sadly is not going away despite the general knowledge in the legal community that AI can hallucinate and make up cases. AI hallucination has been reported on extensively in media (not just in the legal context, but at large) and the subject of many seminars and continuing legal education trainings offered by bar associations, articles written in legal journals, and numerous well reported instances of courts sanctioning attorneys.
Docket entry 537, 10 July 2025 · source · PDF · 3 pages
Docket text. ORDER as to Glennie Antonio McGee re: Dft's 509 MOTION to Continue in Interest of Justice, Dft McGee's counsel is to show good cause why they should not be sanctioned NLT 4:00 pm on 7/14/2025 as set out. Show Cause Hearing set for 7/16/2025 at 09:00 AM in US Courthouse, Courtroom 3B, 155 St. Joseph Street, Mobile, AL 36602 before District Judge Terry F. Moorer. Signed by District Judge Terry F. Moorer on 7/10/25. (tot) (Entered: 07/10/2025)
532, filed 7/10/25).1 In the response in opposition, the United States indicates that counsel for Defendant McGee appears to have fabricated citations in that he cites “ several nonexistent cases, attributing false quotations to others, and directing this Court to precedent that the Supreme Court reversed more than 40 years ago.
532 at 1. In t he opposition, the United States describes at length the bases for his belief that counsel for Defendant McGee fabricated citations. Id. at 5-8.
Case 1:24-cr-00112-TFM-N Doc# 537 Filed 07/10/25 Page 1 of 3 PageID# 6502 Page 2 of 3 In the light of the seriousness of the accusation, the Court has conducted independent searches related to the citations at issue. Regarding the cases that allegedly do not exist, the Court’s search resulted in the same issue as the allegation made by the United States – in that the cases were not found. Citations did not go to the referenced names and the cases did not relate to the issues at hand.
(Central Daylight Time) on Monday, July 14, 2025. Counsel is ORDERED to append to their filing copies of each allegedly fabricated legal authority; if they cannot provide such copies, counsel is further ORDERED to submit a sworn declaration that provide s a thorough explanation for how the motion and allegedly fabricated cases were generated. Counsel is further ORDERED to appear at a show cause hearing at 9:00 a.m.
Docket entry 537, 10 July 2025 · source · PDF · 3 pages
Docket text. ORDER as to Glennie Antonio McGee re: Dft's 509 MOTION to Continue in Interest of Justice, Dft McGee's counsel is to show good cause why they should not be sanctioned NLT 4:00 pm on 7/14/2025 as set out. Show Cause Hearing set for 7/16/2025 at 09:00 AM in US Courthouse, Courtroom 3B, 155 St. Joseph Street, Mobile, AL 36602 before District Judge Terry F. Moorer. Signed by District Judge Terry F. Moorer on 7/10/25. (tot) (Entered: 07/10/2025)
532, filed 7/10/25).1 In the response in opposition, the United States indicates that counsel for Defendant McGee appears to have fabricated citations in that he cites “ several nonexistent cases, attributing false quotations to others, and directing this Court to precedent that the Supreme Court reversed more than 40 years ago.
532 at 1. In t he opposition, the United States describes at length the bases for his belief that counsel for Defendant McGee fabricated citations. Id. at 5-8.
Case 1:24-cr-00112-TFM-N Doc# 537 Filed 07/10/25 Page 1 of 3 PageID# 6502 Page 2 of 3 In the light of the seriousness of the accusation, the Court has conducted independent searches related to the citations at issue. Regarding the cases that allegedly do not exist, the Court’s search resulted in the same issue as the allegation made by the United States – in that the cases were not found. Citations did not go to the referenced names and the cases did not relate to the issues at hand.
(Central Daylight Time) on Monday, July 14, 2025. Counsel is ORDERED to append to their filing copies of each allegedly fabricated legal authority; if they cannot provide such copies, counsel is further ORDERED to submit a sworn declaration that provide s a thorough explanation for how the motion and allegedly fabricated cases were generated. Counsel is further ORDERED to appear at a show cause hearing at 9:00 a.m.