Jackson Jambalaya

The city of Jackson's attorneys caught the hallucinations bug up in Ridgeland as they got caught citing ordinances that simply did not exist.   

The Ridgeland Board of Ealdormen approved a conditional use permit forc onstruction of a power plant at 1972 County Line Road in April 2025.  The plant will be used to provide electricity to the AWS facility.  

The city of Jackson, Richwood Estates HOA, Lakeover HOA, Norwood HOA, and Valley North Improvement Association challenged the permit's approval in Madison County Circuit Court a month later.   The plaintiffs argued the Board ignored its own zoning ordinances in approving the permit.  

Attorneys Scherrie Prince and Samuel Begley represent the city of Jackson while John Scanlon and Jerry Mills represent Ridgeland.  

The case went through the various motions as a motion to dismiss and its various responses were filed.  Entergy, MCDEDA, and Environmental Advocates of Mississippi jumped into the fray as well as they joined the lawsuit or filed amicus curiae briefs.   

Madison Circuit Court Judge Steve Ratcliff denied the motion to dismiss.  Thus began the battle of the briefs.  

Problems arose when Jackson submitted its reply brief.   The brief quoted Ridgeland zoning ordinances that did not exist.   Ridgeland pointed out the hallucination in its brief: 

Appellants also argue that Ridgeland’s Zoning Ordinance requires “documentation establishing that posted notice occurred” pursuant to Section 600.15(C), “proper mailed notice where required” pursuant to Section 600.15(F), and “new notice for continued hearings” pursuant to Section 600.15(D) ([Doc. 53] at 20); however, these cited provisions are not found within Ridgeland’s Zoning Ordinance or any amendments thereto. (City of Ridgeland Zoning Ordinance [Doc. 42-1; 000494-496; 000522-580].) However, even if these cited provisions were in Ridgeland’s Zoning Ordinance, as stated supra, Ridgeland complied with all notice requirements, and there was no violation of Due Process. (Top of page 27 in brief posted below)

Ms. Prince took a turn in the hot seat as Judge Ratcliff grilled her about the hallucination at a May hearing:

MR. SCANLON: And I can wrap up here momentarily, Your Honor. And I think I would agree with the Court. We looked at -- 400 So.3d 474 is where that opinion begins, but the pinpoint site relied on by the appellant's in its brief is Page 481 of that reporter. And that pinpoint 481 is a recitation of the general standard of review for arbitrary, capricious, substantial evidence, but it never talks about the subordinate findings. And as I mentioned, it would be an unusual proposition of law there because the subordinate body of the zoning board actually went along with the Board of Aldermen. I mean, they were aligned. They made the same finding. I would say that the other case -- speaking of cases that are difficult to pronounce, there's one case relied on by the appellant. I think it's a Okhuysen case, O-k-h-u-y-s-e-n, which is 333 So.3d, pinpoint site 579. The appellants relied on that in the briefing to say that a municipality must reconcile conflicting evidence or explain its rejection of it, but I can't find that from that opinion either. The words reconcile, conflicting, rejection, or any related form are just simply not in that opinion. And there was another thing that was concerning about the lack of authority. And I know the Court knows, you know, when you don't have a supporting point, you're not obligated to address it, which was Page 19 of the brief that was filed by the appellants. Excuse me. This is Page 19 from the City of Ridgeland's brief, but it's responding to the brief filed by the appellants where they rely on several non-existent provisions. So, for example, Ms. Prince earlier today talked about 600.15(A) and (B). Those exist. That's the general form of notice. It says if you have a conditional use, it should look like this. Rezoning looks like that, so on, and so forth. But then the appellant's principal brief cited 600.15(C) that doesn't exist, 600.15(F) that doesn't exist, and 600.15(D) that doesn't exist. Didn't exist in the one that's in the record, including all the amendments thereto, and it doesn't exist in the one that's in 2026. Now, I don't know if that's from a separate zoning ordinance. Perhaps it was an inadvertent error, but I want to say that the argument that was made there was we're violating all of these proper mailed notice things that she's citing to provisions, or whoever wrote the brief is, that are provisions from zoning ordinances that just aren't there. 

THE COURT: Ms. Prince, can you reply to that?

MS. PRINCE: Yes, Your Honor. One, I apologize for the oversight. And, two, I would like to bring to the Court's attention that during the time that the briefs were filed -- these were December -- 05/25, around the first of the year. Your Honor, during that period of time, I used Paraprofessional Paralegal Assistants, and not just in this case, but there are other cases where there have been instances where there has been authority that has been cited. Because my firm does use AI, but we use it ethically, and we have a system to use it. But during this time, I was out. And it's of record. It's been in the paper and other places where there have been instances where I have not caught this. And, Your Honor, as I was preparing today, I did not catch this, but that may be the reason that it is there. It is not intentional, but it is something that has been addressed publicly; and the time period is the same that all this -- during this same period when I was out and required additional assistance. I don't -- if it pleases the Court, we would ask that these portions of the record not be considered or stricken as it relates to the Court's consideration of the arguments. And I do apologize for the inadvertent -- for this being inadvertently in here, Your Honor.

THE COURT: Mr. Scanlon, would you tell me those provisions once again?

MR. SCANLON: So 600.15(C) as in Charlie, (D) as in Delta, and (F) as in Foxtrot, are all cited, I think, in the principal brief, and those are provisions that are not in the City's zoning ordinance.

THE COURT: Okay. Thank you. All right. Anything else?

The case is pending.  However, this is not Ms. Prince's first brush with hallucinations.  JXN Water called her out on it when she represented the infamous Blossom Apartments.  WLBT reported April 29:  

Prince asked for permission to refile pleadings after JXN Water pointed out errors in the counterclaim caused by AI.

Wilson said Prince should not be allowed to do so because the defendant failed to show “excusable neglect and good faith.”

“Good faith requires more than filing a brief after the fact. It requires showing the party acted with candor and diligence with the court,” she said. “A filing that cites non-existing authority, misrepresents precedent, does not follow that standard.”

“At a minimum, it reflects a reasonable lack of standard in presenting evidence to the court,” Wilson added.

Prince apologized for the mistake, explaining that an assistant used AI to craft the counterclaim and that she should have paid more attention to it.

“This was a period of time I was going through several physical issues. I have a small firm. I relied on someone to assist me, and I did not supervise them properly, and I admitted that,” she said. “We use AI every day at my firm, and we try to use it ethically.” Article

Judge Wingate took no action against Ms. Prince regarding the hallucinations despite JXN Water's protests.   

Kingfish note: As stated last week, lawyers are not getting the message as they keep getting caught misusing AI to draft their pleadings.  Judge Ratcliff should hammer Ms. Prince.  Fine her several thousand dollars and report them to the Bar.