Rodney v Gee'z Micro Bar: a County Court refers two solicitors to the SRA over AI-suspected fake citations

The problem

Generative AI tools can produce fluent legal text that cites authorities which do not stand for the propositions claimed, or do not exist as cited, and when lawyers file that output without checking it, false authorities enter the court record. His Honour Judge Grimshaw opened his judgment by recording that “the issue concerned the use of artificial intelligence, which I will just refer to as ‘AI’ for the purposes of this judgment, by the Appellant’s then solicitors, AML Legal Solicitors and Commissioners for Oaths” (source). The matter arose in an appeal from a small-claims judgment at the County Court at Dudley, sitting at Walsall Appeals Centre (source).

What was built

There is no deployment to celebrate here — this is an AI-governance honest-negative. The court found that three documents filed in support of the appellant’s application for permission to appeal “contained incorrect citation of legal authorities with the suspicion, at the very least, that those documents had been created using AI” (source). Among the tell-tale features, a stray note reading “Relevance: your client was a litigant in person” appeared inside a list of authorities, which the judge said “suggests … that the document appeared to be advice churned out by a system utilising artificial intelligence as opposed to a document that had been drafted by a human lawyer” (source). The responsible consultant solicitor, Mahmood Hussain, “accepted that the paralegal may have used AI and that the summaries prepared should not have been included within the appeal bundle” (source). Reporting the case, the Law Gazette summarised that “the court heard that three documents were submitted by AML Legal in support of its client’s application for permission to appeal in a civil dispute [and] these contained incorrect citation of authorities with the suspicion that the documents were created using AI” (source).

The outcome

The judge held that placing mis-cited authorities before the court, “when even the most simple of checks would have shown that not to be the case … is inexcusable on the part of a professionally qualified lawyer” (source). He declined to initiate contempt proceedings, finding it “unlikely there would be sufficient evidence to ground a suggestion that there was a deliberate attempt to place misleading material before the court … [so] the threshold stage is unlikely to be met” (source). Applying the Divisional Court’s guidance in Ayinde, he concluded that “given the material was deliberately, albeit probably negligently, deployed, admonishment alone is insufficient” (source), and held that “both solicitors ought to be referred to the Solicitors Regulation Authority so that their regulatory body can decide whether any further action should be taken against either solicitor personally” (source). He directed that “a transcript of this judgment be prepared at public expense and be published on the Judiciary website [and] a copy shall be sent to the Solicitors Regulation Authority” (source). The Law Gazette reported the outcome firsthand, naming both lawyers: “His Honour Judge Grimshaw said the failures of Kossar Qureshi and Mahmood Hussain were so serious that their regulator had to decide whether to take any further action against them” (source), and that “two more solicitors have been referred to the Solicitors Regulation Authority over the submission of AI-generated authorities to court” (source). No fine or wasted-costs sum was imposed: the outcome is a published judgment plus SRA referral of both solicitors.

On the AI attribution — the honest limit, named where you meet the claim: the court did not find that the solicitors used ChatGPT or any named product. The AI origin is stated as a suspicion, and the contempt threshold was held not to be met precisely because the failures were negligent rather than a deliberate, knowing attempt to mislead (source). This is the honesty guard on the whole story: read it as “mis-cited authorities the court believed were probably AI-generated”, not “the court found the firm used a chatbot”.

On the weakest load-bearing source: apart from the primary judgment, this story currently rests on a single independent newsroom — the Law Gazette (a Law-Society-published but editorially independent trade title). It names both solicitors and the SRA referral firsthand, but it is one secondary, not two, so the corroboration beyond the court’s own record is thinner than on a case carried by several nationals. The archive byte-tie, open when this was first researched during an Internet Archive outage, is now closed: the judiciary.uk transcript byte-ties to an organic Wayback capture and the Law Gazette article is separately archived.

Verification status: PENDING — the checker graduated this at confidence 1.000 (both critical claims two-independent, archive byte-tie closed); the green verified badge is human-only and awaits the owner’s sign-off.

Path to green

The court-stated facts need no client or subject confirmation: the origin is a published, citable County Court judgment (ref M00DD215), retrieved this session from judiciary.uk and preserved as a local capture (sha1-b32 A5Z5Q53B26N65VRDLX4I554JMH6CTU25). The archive byte-tie is now closed: the judiciary.uk transcript decompresses from its organic Wayback capture (20260716075945) to bytes identical to the local copy (256,735 B, same sha1-b32), and the Law Gazette article is archived at Wayback 20260515042721 with all cited quotes verbatim. What the record could still add as an optional lift: a second independent newsroom (solicitornews.co.uk and regulationandcomplianceoffice.co.uk both covered it) restating the SRA referral of both named solicitors firsthand. The green badge is not the checker’s to grant: verified is human-only, so this rests at pending for the owner’s sign-off.

How this was verified

• Method: Every quoted finding was read verbatim from sources fetched this session and matched against the local pdf-parse extraction of the judgment. No number or holding is paraphrased, rounded, or recalled.
• Primary anchor: The independent-origin County Court judgment of HHJ Grimshaw, approved 23 April 2026 (transcript ref M00DD215, “Dudley Appeal 18 of 2025”), retrieved from judiciary.uk; local copy sha1-b32 A5Z5Q53B26N65VRDLX4I554JMH6CTU25.
• Standard: Court-origin. The outcome is the adjudicated referral, so the public record — not any subject’s confirmation — is the proof; green never depends on the sanctioned lawyers or the court agreeing.
• Independence: The Law Gazette independently restates the mis-citation and the SRA referral of both named solicitors firsthand.
• Archive: Byte-tie closed by the checker. The judiciary.uk transcript’s organic Wayback capture (20260716075945) decompresses to bytes identical to the committed local copy (256,735 B, sha1-b32 A5Z5Q53B26N65VRDLX4I554JMH6CTU25); the Law Gazette article is archived at Wayback 20260515042721 with all cited quotes verbatim.
• Checked on: 2026-08-20 (checker round 2 — graduated to pending, confidence 1.000).

Related case files

• Ndaryiyumvire v Birmingham City University (County Court at Birmingham) — wasted costs and SRA referral after AI-fabricated authorities from case-management software — the closest sibling: another County Court applying the same duty-to-verify to a solicitor whose research tool produced fake cases, cited as guidance in this very judgment.
• Ayinde v Haringey (England & Wales Divisional Court) — the landmark UK ruling HHJ Grimshaw applied — the precedent on the robust approach and on why admonishment alone rarely suffices, expressly relied on here.
• Bandla v SRA (England & Wales High Court) — fabricated citations where AI use was denied — a UK counterpart on the attribution problem: fabricated authorities where the AI origin was suspected but not established.
• McCarthy v DEA (3d Cir.) — non-monetary discipline for AI-fabricated authorities — a US appellate court reaching a non-monetary sanction where this County Court, too, chose referral over a fine.

Sources

1. [Tier 1] Courts & Tribunals Judiciary — Sabrena Rodney v Gee’z Micro Bar & Pitstop and others, County Court at Dudley (sitting at Walsall Appeals Centre), HHJ Grimshaw · ex tempore judgment (transcript ref M00DD215) · 23 April 2026 · https://www.judiciary.uk/wp-content/uploads/2026/05/Transcript-of-judgment-re-contempt-M00DD215.pdf
2. [Tier 2] Law Gazette · “Judge refers solicitors to SRA over ‘inexcusable’ submission of AI-generated authorities” · 2026 · https://www.lawgazette.co.uk/news/judge-refers-solicitors-to-sra-over-inexcusable-submission-of-ai-generated-authorities/5126797.article