By Mike Scarcella
WASHINGTON, May 5 (Reuters) - The Georgia Supreme Court on Tuesday disciplined a prosecutor in the U.S. state, finding her misuse of artificial intelligence tools led to fake and misleading case citations appearing in a murder case ruling.
The state's high court barred Deborah Leslie, a Clayton County assistant district attorney, from appearing before the justices for six months and ordered her to complete additional legal education on ethics, brief writing and proper AI use.
The court
found that "numerous fictitious or misattributed case citations" appeared in a lower court’s 2025 order denying a murder defendant’s bid for a new trial.
“Citing cases that do not exist or do not support the proposition for which they are cited is a violation of this Court’s rules and falls far beneath the conduct we expect from Georgia lawyers,” Justice Benjamin Land wrote.
SOME ATTORNEYS FAIL TO VET AI RESULTS
State and federal courts across the country have disciplined attorneys for using generative AI tools for legal research and drafting without vetting the results. The Georgia case is among the rarer instances involving a prosecutor's use of AI, and stands out because the lawyers' AI errors were repeated in a court opinion.
Leslie and the Clayton County District Attorney’s Office did not immediately respond to requests for comment. Leslie apologized in an earlier court filing for failing to independently verify the AI-generated citations.
The sanction came in the appeal of Hannah Payne, who was sentenced to life in prison plus 13 years for the murder and false imprisonment of Kenneth Herring.
Leslie's AI-generated false citations appeared in a proposed order she prepared, urging the trial judge to deny a request for a new trial. The judge adopted much of the proposed order, including fabricated citations, in denying Payne's request, the Georgia Supreme Court said.
The state justices on Tuesday urged trial judges to review proposed orders "with the understanding that artificial intelligence software, with all of its potential risks and benefits, may have been used."
The justices vacated the earlier ruling and sent the case back to the trial judge, directing that a new order be issued without fictitious citations.
"Hannah Payne has strong issues for appeal. It is a shame that the State's misconduct is now delaying her opportunity to have those issues be decided," her lawyer, Andrew Fleischman, said in a statement.
(Reporting by Mike Scarcella; Editing by David Bario, Rod Nickel)
