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

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 (source). The Supreme Court of Alabama found that those briefs “contain numerous invalid, inaccurate, and/or irrelevant citations to legal authorities” (source). In the Court’s words, they “appear to be artificial-intelligence (“AI”) “hallucinations,” i.e., fake authorities created by an AI system,” and most of the authorities were “misquoted or nonexistent” (source).

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, and the order does not name any specific AI product (source). On January 26, 2026 the Court ordered Hall to appear at a February 4 show-cause hearing over the briefs (source). At that 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” (source). He self-reported to the Alabama State Bar, and on February 9, 2026 notified the Court that he had delivered a check for $17,200 to the appellee’s counsel, the estimate of the fees and costs incurred responding to the fabricated authorities (source). Reporting independently, Lowering the Bar confirms that “a week later he wrote the other side a check for $17,200” (source).

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” (source).

• Attorney fees and costs to the appellee: $17,200, “this amount includes any amount that has already been paid to Bruce” (source).
• Appellate costs payable to the Court: double costs (source).
• 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” under Rule 25A (source).
• Referral to the Alabama State Bar for potential discipline (source).

The $17,200 award is attorney fees and costs to the appellee, distinct from the double appellate costs, and the underlying trust merits are unrelated to the AI conduct (source).

How this was verified

Court-origin, re-checked live on 2026-08-11. The primary source is the published Supreme Court of Alabama opinion in Ibach v. Stewart (SC-2025-0106, released April 24, 2026), byte-tied to Wayback capture 20260724211555 (sha1 e01b96f3c7dd35a3daa27fe7daa219a9b8528398). Every figure and quotation on this page was re-checked against that opinion, and the $17,200 sanction is corroborated firsthand by two independent newsrooms, 1819News and Lowering the Bar (the latter re-fetched live this run). Because this is a court-origin record there is no client to confirm a number: the badge rests on the public court document, not on any party’s say-so. The one thing the record does not supply is the name of the AI tool, which the order deliberately does not identify. A reader can confirm the sanction 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).

Related case files

• Prososki v. Regan, the closest sibling: another state supreme court that struck a brief for fictitious AI citations, dismissed the appeal, and referred counsel for discipline.
• Kruse v. Karlen, where the South Dakota Supreme Court sanctioned a frivolous appeal built on fabricated citations, the same Rule 38 frivolous-appeal mechanism at work here.
• Johnson v. Dunn, the federal hallucinated-citations case the Alabama opinion itself cites as it surveys the wider AI-hallucination problem.
• Noland v. Land of the Free, a California appellate court’s first published opinion on AI-fabricated citations, the appellate analogue to this Alabama first.

Sources

Tiers: Tier 1 = primary (the court’s own opinion); Tier 2 = independent press naming the parties. Figures re-checked live on 2026-08-11.

1. Supreme Court of Alabama, Ibach v. Stewart, No. SC-2025-0106, opinion (McCool, J.), released 2026-04-24 (Tier 1, primary court document; byte-tied to Wayback capture 20260724211555, sha1 e01b96f3c7dd35a3daa27fe7daa219a9b8528398). https://fingfx.thomsonreuters.com/gfx/legaldocs/znvnmqrwqpl/Alabama%20Supreme%20Court%20-%20AI.pdf
2. Lowering the Bar, “The Mistake Will Not Recur,” 2026-04-29 (Tier 2, independent legal-affairs newsroom naming the case and the $17,200 check; re-fetched live 2026-08-11). https://www.loweringthebar.net/2026/04/the-mistake-will-not-recur.html
3. 1819News, “Alabama Supreme Court sanctions Mobile attorney W. Perry Hall for improper use of AI,” 2026-04-25 (Tier 2, independent Alabama newsroom carrying the $17,200 firsthand; confirmed against its 2026-04-25 Wayback capture, live page returned 403 to this run’s fetch). https://1819news.com/news/item/alabama-supreme-court-sanctions-mobile-attorney-w-perry-hall-for-improper-use-of-ai