A federal judge in Alabama sanctioned three Butler Snow lawyers last week after they got caught citing non-existent cases generated by AI.
The tale of technical woe began in 2021 when Frankie Johnson, an inmate in Alabama state prison, sued the Alabama Department of Corrections after he was stabbed 20 times in less than eighteen months. His complaint complained the prison system could not keep him safe due to overcrowding, rampant violence, poor staffing, and corruption. The Alabama Attorney General hired Lord Snow to represent the state.
Butler Snow's lawyers submitted filings replete with non-existent cases as they used ChatGPT for research. When the fraud came to light, a furious U.S. District Judge Anna Manasco held a show cause hearing in May in Birmingham. Judge Manasco said she was going to take a long look at how to sanction the lawyers as she noted fines and sanctions in similar cases around the country have failed to deter the misuse of AI in research. She said the Butler Snow case was "proof positive that those sanctions were insufficient. If they were, we wouldn't be here"
Judge Manasco pronounced judgement on June 23 and pulled no punches:
Three attorneys for Defendant Dunn (Matthew B. Reeves, William J. Cranford, and William R. Lunsford) confirmed in writing and at a hearing that the citations were hallucinations of a popular generative artificial intelligence (“AI”) application, ChatGPT. In simpler terms, the citations were completely made up.
The Court noted reprimands and "modest fines" have done little to combat AI abuse while slamming the Attorney General: "And in any event, they have little effect when the lawyer’s client (here, an Alabama government agency) learns of the attorney’s misconduct and continues to retain him."
Judge Manasco publicly reprimanded all three lawyers, ordered the publication of her order, disqualified them from the case, and referred the matter to the Alabama State Bar for prosecution.
Lord Snow itself escaped sanctions due to its independent investigation. The law firm reviewed all Alabama federal court dockets and did not find any additional "AI-generated hallucinations." It hired an independent law firm, Morgan Lewis & Bockius) to conduct an independent review. Morgan Lewis reviewed 2,400 citations in 330 filings and found no misuse of AI.
Indeed, Butler Snow warned its attorneys against relying too much on AI in a June 2023 email:
Mr. Watson stated that in June 2023, all Butler Snow attorneys received an email “stating that ‘there are significant risks that LLM [Large Language Model] output can appear perfectly researched and logical while in fact it is wholly inaccurate.”
The prestigious law firm did not fight sanctions but told the Court it was prepared to accept judgment.
Judge Manasco said she could not sanction them under Rule 11 because the violations pertained to discovery motions. Discovery apparently has some exemptions under Rule 11 as it is governed by other rules.
Mr. Lunsford’s request to be excused from the show cause hearing reflected an intense lack of concern for the seriousness of the misconduct.... According to Mr. Lunsford’s own testimony, he did not make any effort to verify the contents of the motion to compel before authorizing its filing, and it would have been extremely unusual for him to do so.... Like Mr. Cranford and Mr. Reeves, Mr. Lunsford simply assumed the truth of what was in the draft, and/or assumed that someone else would check on that. To be clear, the court’s finding in this regard is not simply a harsh inference: when it became apparent that multiple motions with his name in the signature block contained fabricated citations, Mr. Lunsford’s nearly immediate response was to try to skip the show cause hearing and leave the mess for someone else. And when the court compelled him to appear at the hearing, he paired his apology with an explanation in greater fullness of how very little work he personally puts in to be sure that his team’s motions tell the truth. This cannot be how litigators, particularly seasoned ones, practice in federal court or run their teams. Accordingly, the court will impose an appropriate sanction under its inherent authority.
Judge Manasco ordered the threesome to provide a copy of the order to their clients, opposing counsel, and every court in "every pending state or federal case in which they are counsel of record."
43 comments:
Meanwhile the plaintiff still in prison got stabbed 18 more times.
IT here - this is where my prediction of AI running shit off the rails is coming to fruition. We are not going to advance the way all the optimists have said we are. It's going to be misused by lazy people, which is going to discredit it's benefits and make people distrust it. Remember, something can work well (people or mechanisms) consistently for a long time, but the second a seed of doubt is planted, all of that goes out the window. People don't have patience for mistakes.
It is deeply satisfying to watch this unfold and it could not have possibly happened to a more worthy set of stuffed shirts and loafers.
This just blows my mind. Attorney just used made up info. I just dont get how this happens. Lawyers and paralegals should research then file docs with the court. At what point do you just make stuff up?!
ooops!
Apparently Judge Wingate is thought to have done the same thing recently.
At 9:49 a different IT here.
The biggest problem is hallucinations caused by injecting DEI nonsense into the LLM. China’s DeepSeek excludes a lot of this. Of course, it injects a lot of CCP propaganda. But Many of the earlier gen models were better becauss they would give you honest answers about stuff like racial crime stats and the martyrdom of St Thomas. Now they have tinkered too much under the hood.
Human lawyers can never be replaced by AI. Because, as is said of lab rats as well, there are things even AI would never do.
It’ll be forgotten….well now
"when it became apparent that multiple motions with his name in the signature block contained fabricated citations, Mr. Lunsford’s nearly immediate response was to try to skip the show cause hearing"
He must be VERY important if he can't be bothered with such trivialities as a show cause hearing, for a pleading he signed.
Alternate headline: Judge Serves Humble Pie.
Hey, I get it. Reviewing legal documents is incredibly boring, and checking primary sources is both hard and boring. If I were going to do that, I might charge $300 - $600 per hour...oh, wait, you did charge your clients that much. Or, was it more. So, for that much money, you couldn't be bothered to actually check the referenced sources? At those rates, you still just assumed things? Once again, the relationship between cost and value is disproven.
Word on the street is that Lunsford is disliked within Butler Snow but as at all law firms, he who has the clients has the power.
Certain disbarment, oh that’s right, this is Mississippi.
From the same fine lawyers who actively helped run/promote the Timber Ponzi (with e-mails to prove it) and then paid off their fine with PPP money without a single disbarment to show for it.
How these clowns stay in business, much less hold such an esteemed position in this backwater state is beyond me.
Obviously Madame Your Honor Ma'am, doesn't have the authority to level monetary penalties or she would have.
Next Saturday afternoon you will find this trio of barristers on the sixth hole laughing and slapping their knees.
this firm was started in mississippi. for decades it was considered the gold standard for legal representation.
however , just in the past few years , after being heavily involved in the lamar adams timber company ponzi scam, this firm goes out and pulls this fake citation scam and basically perpetrates a fraud on the court.
back in 80s many of the partners of the jackson office were good friends of mine.
most have passed on, but thank god they were not around to see this.
by the way, i been practicing law in this town since reagans 2nd term in the white house.
Wingate can sleep well since the shit only runs downhill in the law trade.
Those who know label LLMs as "Slop Generators."
These Butler Snow clowns could have served their clients better by just LMGTFY.
The arrogance of Butler Snow in general is astounding. I have no sympathy for the firm or the lawyers themselves in this case. I am sure the client was charged a full amount as if though a lawyer had done the research and written it without the use of AI. I also agree that if the lawyer signing off on the pleading was too inconvenienced to review it, then he has no business practicing law.
Ka ching!
"Lunsford and Butler Snow have been awarded millions of dollars to represent the Alabama Department of Corrections in cases alleging abuse within Alabama’s prison facilities.
In December 2024, the Contract Review Committee approved contracts totaling $4.8 million to Lunsford and Butler Snow. The committee had previously approved $14.9 million in July 2023 and another $7.68 million in June of that same year."
https://alabamareflector.com/2025/05/21/federal-judge-mulls-sanctions-for-attorneys-who-used-ai-in-court-filing/
Seems like, with the money they charge per hour, they could have actually done the work themselves. I guess looking like assclowns and utterly incompetent was a better position.
There are lots of AI written doctoral theses out there.
10:33 - Relevant info - good point.
"Certain disbarment, oh that’s right, this is Mississippi"
Er, no, it's Alabama and none of the three are licensed in Mississippi, so the MS Bar (and MSSC) has nothing to do with this. On top of which, Anna Manasco is from Alabama, was a partner with BABC in Birmingham, nominated by Trump (first term) and was something like 75-25 on the vote.
These three have a serious problem and BS has yet another very serious one. As noted in the cat lawsuit thread, screwing around with any federal judge is not smart, but screwing around with certain ones can be (actual or tacit) career suicide. I'm guessing from her order that she is not...amused...by the antics of these three stooges.
Kingfish loves to take potshots at "Lord Snow", the law firm from which I am now retired. I joined the firm in 1985. I was lawyer #41. The firm now has well over ten times that number.
I recently read a fascinating interview in Mississippi Today with Tommy Duff, one of our homegrown billionaires. He and his brother inherited Southern Tire Company out of Columbia, with seven employees, and built it into a behemoth. Few Mississippians, myself included, had ever heard of them until they finally started getting attention in the last few years.
I know Kingfish, and both like and admire him. I have no problem with his "Lord Snow" gambit; it attracts eyeballs. But what's missing is a simple statistical analysis. With larger numbers, the odds increase that mistakes will happen. The interview with Mr. Duff did not touch on Southern Tire's mistakes, but common sense will tell you that they happened, and that his business rivals played them up. Of course I'm distressed to read anything negative about my beloved former law firm, but I would hope that they be considered (as several commenters have done) in the context of the remarkable growth of a Mississippi business, and how much larger it is than any other Mississippi-based firm. Lawyers are too often vilified, sometimes with good reason, but in the larger scheme I propose that Mississippians should mostly be proud when our native sons and daughters are as successful as Butler Snow and so many other enterprises.
Butler Snow has in the past few years acquired a few smaller firms that used to represent state/county/city entities to get a stranglehold on that market in MS
"Dear All My Clients,
I hope you are having a great week! Mine has been a bit of a sticky wicket. Please find enclosed the benchbeating a federal judge ordered me to send to you. I'm pretty sure that I've probably not fucked up anything in your case(s), at least not this badly, but we're still checking that part out. In closing, I'd like to beg you not to fire my stupid, arrogant, incompetent, over-priced, over-charging ass.
Please. Dear God, PLEASE?
/S/ Your VERY expensive lawyer"
This was in Alabama regarding an Alabama case and Alabama lawyers...
Is this a Mississippi occurrence?
Attorneys were left perplexed by an order from a federal judge in Mississippi containing "apparent indisputable factual inaccuracies," prompting concern over how such errors could have occurred and whether artificial intelligence (AI) was to blame.
https://lawandcrime.com/high-profile/never-seen-anything-like-this-lawyers-bewildered-over-federal-judges-order-rife-with-indisputable-factual-inaccuracies/
Which federal judge in Mississippi?
"U.S. District Judge Henry Wingate's July 20 order granted a request for a temporary restraining order (TRO) from several education advocacy groups "
That name, where have I seen that name recently...
Maybe they should specialize in timber related litigation.
"I didn't cause the problem. It's also true that none of the other important and highly paid attorneys at our firm did it.
We are blaming the problem one of the young pups.
It turns out he allegedly was cutting some corners that we claim to know nothing about.
It's a necessary evil that a lot of our scut work is done by the low paid help, as has allegedly happened here.
We can't always be troubled to check their work, sometimes we just examine the polish on the turd before filing it. Due to competoitive and financial pressures.
So anyway, the young pup has been dealt with and things can continue on.
It's good to keep things on a friendluy basis, as one never knows when the revolving door will deposit us into a different camp."
P.S. be sure to file under work product!
Loyal like an ole dog
Good thing you quit law before AI.
Dan Hise wrote, "...my beloved former law firm...," which he joined in 1985 as #41.
I, too, read the Duff piece. And like STM or the Duff brothers themselves, Butler-Snow is not the same as it was "way back when." The firm which you joined no longer exists as it did then. This was not a "mistake." It was a crime of hubris and arrogance, enhanced by the nose-thumb to a federal judge when caught. Let me ask you this: would you want any of these three as partners? And why or why not?
One of the best guys to practice - well said Don Clark acting like Dan
Nothing will happen: nothing will change.
On to the next client and billable hour.
Those lawyers better update their resumes.
The same William Lunsford has been paid (or has a contract to be paid) nearly $2 million by the Mississippi Department of Corrections. Look it up on Transparency.
Are you excluding making bonehead mistakes like this one from your comments, or are you including all mistakes? Everyone makes mistakes, but isn't it more than a little less than genuine to say that this was an honest mistake? Of course I have made mistakes as an attorney, but I do my best every day to avoid them, regardless of how busy I am. The remarkable growth of Butler Snow should have no bearing on this particular fact pattern. Adding attorneys who do not even proof their work means the firm isn't vetting their acquisitions well enough. Perhaps the firm should slow down its growth until it can get a grip on things.
The law cites are real, Butler Snow is fake.
Dear Mr. Hise: You should be very proud of what Butler Snow used to be. But, it looks like all good things come to an end. I know there are a lot of really good intentioned attorneys, but knowing that only small portions of bad attorneys are ever publicly chided, makes it difficult to trust any of them.
The higher priced attorneys are suppose to be better attorneys. Not better at liars, but better at knowing the law or finding the loopholes. Having good morals and making good decisions doesn’t require a law degree or any degree. When has Butler Snow ever done a single thing to raise the bar? A Gold Standard should include having good morals while also being successful. Weird combination, yep. These lawyers now are lazy, Mr. Hise. It will catch up to them. Whether KF reports it, or not. I wish they would do something positive.
If these guys are experts in this practice area, and this was merely recycled language from the myriad other fillings they've signed, it tells me they didn't even glance at what they signed. If they were using the same cites and argument across numerous similar fillings (and there's nothing wrong with that), a mere glance would have caught the new and unfamiliar, or, if some associate managed to find some cases that caused them to diverge from the existing and make new arguments using those cases , that, too, would have jumped out with merely a glance.
Then, there's the sorry, shameful attempts to shove others, especially associates, in front of and under the bus. Anyone condoning such, much less being proud of partners doing such things, is a sorry disgrace themselves. You boys fucked up. Have the stones to stand up and take your licks. If you had been the least bit honorable about any of it, you probably would not be getting what is coming. You deserve that and more. You are why there are "lawyer jokes" and why many of them are funny. Fuck you for that alone, and fuck you hard and dry for the rest.
As to Judge Manasco, please dear lord, let them be 15 seconds late on something ("24 hours" didn't read like "eh, when you get around to it...") or further screw the pooch ("Are you really that stupid to think I meant almost all clients, hoss?"), and may she find out about it at the very instant she spills coffee on her favorite outfit (or something not truly harmful but enough to put her in REAL killin' mood). The Bar has been asked. The Bar has been told. "Forced to comply" is nigh upon us.
Hoo, boy - the dipshitery and jackassery abound, with citations dontchaknow:https://abovethelaw.com/2025/07/biglaw-ai-apocalypse/
This BS (pun intended) in a stain on the legal profession. May they continue to get embarrassed in court by judges who don't give a damn about how important they are.
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