Johnson v. Dunn: three lawyers are disqualified and referred to the bar for filing five ChatGPT-hallucinated citations

The problem

In Johnson v. Dunn (No. 2:21-cv-1701-AMM, N.D. Ala.), a prisoner civil-rights case, incarcerated plaintiff Frankie Johnson accused defendant Jefferson Dunn — the former Commissioner of the Alabama Department of Corrections — “of fabricating citations to legal authorities in two motions.” The two motions had been filed by three of Dunn’s attorneys at Butler Snow LLP. The court issued an order to show cause, and the attorneys’ account made the cause plain.

What was built

Three attorneys for Dunn — “Matthew B. Reeves, William J. Cranford, and William R. Lunsford” — “confirmed in writing and at a hearing that the citations were hallucinations of a popular generative artificial intelligence (‘AI’) application, ChatGPT.” In the court’s words, “the citations were completely made up.” “In total, there were five problematic citations across two motions.” An independent account (EDRM) records that the attorneys “admitted that partner Matt Reeves had used ChatGPT to generate case citations and failed to verify them.” A second, unrelated newsroom reports the same facts: the ABA Journal wrote that “Three Butler Snow lawyers may no longer represent a former corrections commissioner in Alabama because they filed two motions with five ‘completely made up’ case citations produced by ChatGPT, a generative artificial intelligence application, a federal judge ruled last week,” and that among the three were “partner and assistant practice group leader Matthew B. Reeves, who said at a show-cause hearing the fake citations were due to his use of ChatGPT.”

The outcome

On July 23, 2025, Judge Anna M. Manasco held that fabricating legal authority “demands substantially greater accountability than the reprimands and modest fines that have become common as courts confront this form of AI misuse.” The order states: the court “PUBLICLY REPRIMANDS Mr. Reeves, Mr. Cranford, and Mr. Lunsford for making false statements to the court; ORDERS publication of this order to effectuate that reprimand; DISQUALIFIES them from further participation in this case; and REFERS this matter to the Alabama State Bar and other applicable licensing authorities.” No monetary fine was imposed. The court “RELEASES WITHOUT SANCTION attorneys Daniel J. Chism and Lynette E. Potter, and the law firm Butler Snow LLP” — the independent EDRM account notes the court “declined to sanction the firm itself, crediting Butler Snow’s pre-existing AI policies and its robust post-incident response.” The ABA Journal, reporting separately, records the same two points: that “U.S. District Judge Anna M. Manasco of the Northern District of Alabama said fabricating legal authority ‘demands substantially greater accountability than the reprimands and modest fines that have become common as courts confront this form of AI misuse,’” and that “Manasco also publicly reprimanded the lawyers; referred them to the Alabama State Bar; and ordered them to disclose the sanctions order to all clients, the opposing counsel and the presiding judges in every pending state and federal case in which they are counsel of record.” On the firm: “But Manasco did not sanction the law firm.”

Verification status: PENDING — awaiting human confirmation. Not verified.

Path to green

The sanction is stated by an independent federal court in a signed, publicly filed order that is byte-identical across CourtListener RECAP and Courthouse News (both Wayback-archived, same CDX digest) and matches the copy downloaded and quoted here — so the figures need no client-confirmation call to be true. The human step that would earn a green badge is confirming the docket’s post-order posture: whether any appeal or motion to amend was filed (the order was modified 2025-07-24 per the docket), and the disposition of the Alabama State Bar and other-jurisdiction referrals against the three attorneys.