Alabama Supreme Court dismisses appeal, fines lawyer $17,200 for AI-'hallucinated' citations

Verification status: PENDING — checker-graduated (confidence 1.000), awaiting HUMAN client-confirmation. Not verified, not green.

The problem

W. Perry Hall, a Mobile, Alabama attorney, filed an opening brief and a reply brief in the appeal of Ibach v. Stewart (No. SC-2025-0106) — a family dispute over the fiduciary duties of a living-trust trustee. The Supreme Court of Alabama found that those briefs “contain numerous invalid, inaccurate, and/or irrelevant citations to legal authorities.” In the Court’s words: “They appear to be artificial-intelligence (“AI”) “hallucinations,” i.e., fake authorities created by an AI system.” Most of the authorities in the briefs were, the Court found, “misquoted or nonexistent.”

What was built

Nothing was “built” — this is a court-origin AI-accountability record, not a deployment. The relevant conduct is the misuse of an unnamed generative-AI tool to draft legal briefs. At a Feb 4, 2026 show-cause hearing, “Hall admitted that many of the legal authorities in his briefs do not exist and that he improperly used AI to obtain those authorities.” He self-reported to the Alabama State Bar and, on Feb 9, 2026, delivered a check for $17,200 to the appellee’s counsel — the estimate of the fees and costs the appellee incurred responding to the fabricated authorities. The order does not name any specific AI product.

The outcome

Released April 24, 2026, the opinion (McCool, J.) dismissed the appeal as frivolous under Rule 38, Ala. R. App. P., and the Court’s inherent authority, holding the briefs “grossly deficient.” The sanctions:

• “Hall is hereby ordered to pay attorney fees and costs to Bruce in the amount of $17,200 (this amount includes any amount that has already been paid to Bruce)”;
• Hall “ordered to pay double costs” of the appeal to the Court;
• “Hall is prohibited from filing anything else in this Court unless another attorney, who is in good standing with the Alabama State Bar, signs the filing” (Rule 25A); and
• referral to the Alabama State Bar for potential discipline.

It was a divided decision (Justices Sellers and Mendheim concurred in part and dissented in part; Justices Cook and McCool concurred specially). The $17,200 award is attorney fees and costs to the appellee, distinct from the double appellate costs; the underlying trust merits are unrelated to the AI conduct.

Path to green

Court-origin: there is no client to confirm a number, so this record cannot earn a green badge through the usual client-confirmation call. A human verifier can confirm it directly against the official slip opinion on the Alabama Appellate Courts public portal (publicportal.alappeals.gov, case SC-2025-0106) and the Mobile Circuit docket (CV-24-901773). The maker’s copy is byte-tied to Wayback capture 20260724211555.