Monday, December 22, 2025

The $20,000 Hallucination

Did AI trip up yet another lawyer?  A former candidate for Attorney General must pay nearly $21,000 after a federal judge busted her for using phony citations and quotes in multiple filings.

 Greta Kemp Martin is the Litigation Director at Disability Rights Mississippi.  She was the Democratic nominee for Attorney General in 2023 but lost to incumbent Republican Lynn Fitch.  

Disability Rights Mississippi (DRM) sued the Palmer Home for Children in U.S. District Court (Northern Division of Mississipi) in May 2024.  DRM alleged the Palmer Home denied it access to the facility so it could monitor Palmer Home and investigate complaints it claimed are allowed under federal law.  Palmer Home responded it was not subject to DRM's jurisdiction.  

The case was assigned to Senior U.S. District Judge Sharon Aycock.  

Judge Aycock denied DRM's motion for a preliminary injunction and Palmer Home's motion to dismiss. The case continued as the two sides scrummed their way through the legal process.  However, Palmer Home's Butler Snow lawyers found bogus citations and quotes in DRM's motion and notified the Court.  So sloppy was DRM that it submitted a response a week later with the same phony quote.




The Court issued a show cause order to Ms. Martin in April.  The order states: 



Judge Aycock held a hearing on the matter in June.  Martin withdrew from the case in July.   Disability Rights of Mississippi tried to voluntary dismiss its lawsuit in July.  The Court has not ruled on the motion.  

The Court found DRM and Martin submitted three phony cases and six phony quotes in three filings submitted to the Court.  Martin tried to excuse her fraud: 

In her Response [48], Martin explains that she “relied on an internal reference document developed for efficiency in drafting.” [48] at p. 1. Martin admits to committing mistakes; however, she describes the mistakes as “citation errors” and “old-fashioned copy and paste errors.”... As to the fake quotes, Martin explains in her Response [48] that the same were in reality “paraphrased summary lines for internal use only” which she “inadvertently failed to remove… when inserting case citations” resulting in “several filings incorrectly attribut[ing] paraphrased summaries to the courts themselves.” 

Martin claimed at her show cause hearing she did not use AI to craft her pleadings.  The Sanctions Order states: 

Martin expressed embarrassment and regret for her mistakes. She also produced the “internal reference document” and explained that the document was comprised of screenshots from a Microsoft OneNote file, which she had developed and utilized for organizational purposes. The document contains a list of legal citations followed by short phrases in quotation marks. At the hearing, Martin explained that she had revised the document following the entry of the Court’s Order to Show Cause [46] to avoid further mistakes, and, as a result, she was unable to provide the unrevised, original version that she had relied on for preparation of her legal briefs. Martin denied using generative artificial intelligence (“AI”) to draft her legal briefs or to conduct legal research. She did admit, however, to not reviewing some of the cases at issue prior to citing them in her legal briefs and subsequently filing those briefs with the Court.

Martin's shoddy work forced Lord Snow to conduct its own research to respond to Martin's filings.  Palmer Home submitted a claim for expenses of $27,252 to the Court. 

The Court wasn't buying what Ms. Martin was selling.  The Court said "everything that guy just said is bullshit" in a more genteel manner:  

On this point, the Court notes that it disbelieves Martin’s explanations regarding the source of her mistakes and is highly suspicious that she used AI to generate the legal authorities cited in her legal memoranda [38, 40, 43]. As explained in more detail hereinafter, Martin’s filings contain fabricated case citations comprised of some parts corresponding to real cases, but the same are not real cases as cited. Martin also provides a legal citation in one of her filings that does not lead to any existing case. Federal district courts have described these sort of citations as “hallucinatory” citations, which are indicative of AI usage.

Judge Aycock said the wayward attorney was "not honest" with the Court as she hammered away: 

The Court need not address each of the quotes to make its point. It finds that Martin knowingly and deliberately misrepresented in her Response [48] that the fake quotes did not alter the holdings of the cited cases with the intent to mislead this Court. She attempted to perpetuate these misrepresentations at the show cause hearing. She acted in bad faith.

Fed up with Greta Martin, the Court held Lord Snow should not have to pay for the work it did in uncovering the wayward attorney's fraudulent conduct.  

Judge Aycock ordered Ms. Martin to pay $20, 883 to Palmer Home for Butler Snow's attorney's fees by January 18, 2026.    

Ms. Martin resigned her position at Disability Rights Mississippi.  The Court said it would not impute blame for her fraud to her former employer.  

The Court will report the sanctions to the Mississippi Bar.  Ms. Martin must attend a three-hour continuing legal education course on hallucinatory citations.  

 

21 comments:

Anonymous said...

Sounds like disbarment justification to me.

Anonymous said...

This is really bad. Not only did she not check the cites generated by AI, but then she lied to the Court about it which is completely unforgivable. Maybe the Mississippi Bar will actually ask the MS Supreme Court for substantial sanctions against her.

Anonymous said...

She seems qualified to be our AG.

Anonymous said...

When you have young computer geeks without much in the way of life and cultural and social experience or understanding all aspects of human behavior or human priorities, you get "what" , not " why". It's still " garbage in, garbage out" information.

Anonymous said...

Does Antard have any openings? Maybe Rukia needs someone to help pass out bottled water?

Anonymous said...

Greta Kemp Martin is an insufferable obese liberal BITCH. She is just plain disgusting. Couldn't happen to a nicer gal.

Anonymous said...

was not LORD snow caught doing the same thing not long ago?

Kingfish said...

In Alabammy

Anonymous said...

It's probably a good thing Lynn Fitch has a well qualified staff to write whatever she submits.

Anonymous said...

Ol Greta will need some help from Bennie T to make that payment.

Anonymous said...

She got caught, got called out on it, and doubled down to the judge's face. No integrity whatsoever.

Anonymous said...

I have known Greta for 20 years, and she is one of the most honest people I know. That this happened is most unfortunate. I will not believe it was intentional, no matter what was written about it. I, for one, am not polishing my halo, and I would urge these negative Nellies to do the same.

Anonymous said...

The right thing to do would have been for Butler Snow to provide Rule 11 notice and 21 days to withdraw the offending pleading(s).

Anonymous said...

Greta, thanks for checking in.

Anonymous said...

2:35, I was think the same thing.

Anonymous said...

Um. This isn’t Greta, but is someone who has known her for 20 years, as I said.

Anonymous said...

Why exactly did Butler Snow have to spend $30k on this? It only takes a few minutes to write, "this quote/case/whatever does not appear to exist." You were going to have to reply to the brief anyway. Books, reporters, even westlaw lexis etc. are full of mistakes. Why is it a literal federal case when a lawyer relies on AI?

Anonymous said...

Greta, deny, deny, until you die.

Anonymous said...

"Why is it a literal federal case when a lawyer relies on AI?"

Read the opinion. Or better yet, have AI summarize it for you, since it's kind of long.

Anonymous said...

"Ms. Martin resigned her position at Disability Rights Mississippi. The Court said it would not impute blame for her fraud to her former employer."

Of course not. These employers never have a clue they are recruiting and employing shady characters. Entirely coincidental.

It would be like Morgan & Morgan saying, "When we hired him, we had no idea he was an ambulance chaser".

Anonymous said...

Not really. She has at least been in a courtroom!


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