Anything you can do, I can do…worse! 🤣 In Mississippi, lawyers on both sides of a case cited fake hallucinated cases. Sanctions followed.

In the case Withers v. City of Aberdeen, out-of-state lawyers Kathryn Y. Williams and Kathleen M. Wilson used AI for research and drafting, while local counsel Shauncey Hunter Ridgeway and Mark McClinton approved the filings without checking the citations. All received sanctions of varying degrees.

In the Sanctions Order issued by Mississippi Senior District Judge Sharion Aycock, she noted that Wilson and Ridgeway were counsel for the Plaintiff, while Williams and McClinton were counsel for the City. Spoiler alert: the use of the past tense in that sentence was intentional. 😉

Over three filings – two by the City, one by the Plaintiff – the Court determined that the filings contained “hallucinatory citations”, which she proceeded to list.

After the Court entered an Order to Show Cause last December directing the attorneys from both sides to show cause as to why the Court should not impose sanctions against them for their conduct, “the attorneys admitted that the hallucinatory citations cited by them, and identified by the Court, resulted from unverified AI use” and “[e]ach of the attorneys expressed embarrassment and apologized to the Court” in the show cause hearing on January 20, 2026.

That did not save them from sanctions, however.

Wilson’s defense was particularly interesting. As Judge Aycock noted: “Wilson explained that she was shocked when the Court issued the show cause order pointing out the hallucinated cases appearing in her filing. In essence, Wilson took the position that she was unaware that AI could produce hallucinated cases and explained that she did not even know what a hallucinated case was. The Court finds that explanation to be insufficient and incredulous.” She added: “the Court disbelieves Wilson’s claim of ignorance of the risks associated with using AI in the legal context. The Court finds that she knew, or reasonably should have known, of those risks and that she acted in bad faith in failing to verify the legal authority in her AI-generated brief.”

The other issue in Wilson’s case is that the United States Bankruptcy Court for the Western District of Louisiana sanctioned Wilson on April 9 for submitting two filings in March containing “nonexistent cases and statutes as a result of what is universally known as ‘AI Hallucinations’” – two months after the show cause hearing was held before this Court. Big oops!

Conversely, Judge Aycock noted that “Williams indicated that most of the CLEs she attended in 2025 included topics related to AI.” Williams also originally claimed (later recanted) “that she had not violated Rule 11 because the legal propositions in her filings were correct”. Judge Aycock also stated: “It is also apparent that she attempted to minimize the violation by emphasizing that the legal propositions in her filings were correct statements of law despite conceding that she had cited fake cases. The Court finds that those factors combined with her bad faith conduct in violating her firm’s own AI policy, which came to light at the show cause hearing, simply outweigh any mitigation efforts on her part.”

While Judge Aycock stated that she did not factor the conduct into her sanctions decision, she did still observe that Williams “represented that she had a conflicting federal court appearance in another case without providing further detail” for the originally scheduled date of January 6 for the show cause hearing. As Judge Aycock noted: “the Court realized that the remote conference in the New Jersey case had actually been postponed via text order on December 8, 2025—two days before this Court even issued its order scheduling the show cause hearing in this case…The Court is troubled by this misrepresentation and finds that Williams was not truthful about her purported scheduling conflict in violation of her ethical duties as an officer of the court.”

Regarding Ridgeway and McClinton, Judge Aycock found that, as signatories to the filings, both of them violated their duties as a sponsoring resident attorney pursuant to the Court’s Local Rules, but she did find that either of them acted in bad faith.

Sanctions:

Both Wilson’s and Williams’ pro hac vice admission in the case was revoked and both were barred from entering an appearance in any case before the United States District Court for the Northern District of Mississippi for two years. Wilson was also ordered to pay a $2,500 fine and to “attend a CLE on artificial intelligence with an ethics component addressing the obligations of counsel regarding the use of artificial intelligence in the legal field and submit proof of attendance within 60 days”. Williams was also ordered to pay a $3,500 fine.

Both Ridgeway and McClinton were disqualified from further participation in the case and ordered to pay a $1,000 fine.

I’m sure this isn’t the first time that lawyers on both sides of a case have cited fake hallucinated cases. It definitely won’t be the last.

So, what do you think? Are you surprised that lawyers on both sides of a case cited fake hallucinated cases? Please share any comments you might have or if you’d like to know more about a particular topic.

Image created using GPT-4o’s Image Creator Powered by DALL-E, using the term “robot judge doing a faceplant when looking at a computer”.

Sanctions order courtesy of Damien Charlotin’s AI Hallucination Cases database.

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