United States v. McGee: a federal judge fines a court-appointed defense lawyer $5,000 for AI-hallucinated citations produced by a Microsoft Word plug-in called Ghostwriter Legal (2025)

The problem

In two consolidated federal criminal cases against Glennie Antonio McGee — a drug-conspiracy case (No. 1:24-cr-112) and a financial-fraud case (No. 1:24-cr-113) — McGee’s court-appointed CJA counsel, attorney James A. Johnson of Loxley, Alabama, filed a July 3, 2025 motion to continue that contained fabricated case citations (source). The prosecution flagged “several nonexistent cases,” false quotations, and precedent the Supreme Court had reversed more than 40 years earlier — citations that “bear the hallmarks of legal authorities ‘hallucinated’ by artificial intelligence” (source). Judge Terry F. Moorer ran his own searches and confirmed “the cases do not exist” (source).

What was built

Johnson told the court he normally uses Fastcase, but in this instance “he used a Microsoft Word plug-in called Ghostwriter Legal to find additional cases to support the motion” (source). He disclaimed ChatGPT — yet, as the government pointed out, “the very information from Ghostwriter Legal made it clear that it used ChatGPT as its default AI program” (source). He inserted the returned cases without verifying them. That is the distinctive detail in this case file: the AI here was not a standalone chatbot but a research plug-in embedded in Word (source).

The outcome

On October 10, 2025, acting under the court’s inherent authority, Judge Moorer sanctioned Johnson $5,000, payable to the CJA fund (source, source). The order is explicit that it does not rest on Alabama Rule of Professional Conduct 3.3 or Local Rule 83.3(i); Rule 11 is cited only by comparison (source).

The decretal terms, alongside the fine: a public reprimand with a publication requirement across Johnson’s other pending and future cases for 12 months, and submission of the order for publication in the Federal Supplement; referral to the district’s advisory panel to consider removing Johnson from the CJA panel; and a referral to the Alabama State Bar (source, source). The court found the conduct “tantamount to bad faith” (source).

Because this was a criminal case with appointed counsel, the fabrications carried a cost most AI-sanction cases do not. Asked whether he wanted to keep Johnson, McGee said he did not, and new counsel had to be appointed (source). Both trials reset — to January 5, 2026 and February 23, 2026 — which the order calls “a delay of roughly five and six months on the cases,” drawing further on limited public CJA funds (source).

How this was verified

Method: independent verification against the public record, re-run on 2026-08-14. Every load-bearing fact above — the $5,000 figure, the Ghostwriter Legal plug-in, the ChatGPT default engine, the reprimand, the two referrals and the trial resets — was read in the full text of the court’s own Memorandum Opinion and Order on Sanctions (Tier 1) and independently corroborated by three newsrooms with no stake in the outcome: Bloomberg Law, FOX10/WALA in Mobile, and 1819 News (all Tier 2). No party to the case was contacted; TIN verifies against the public record only, never by asking the subject.

One caveat is printed rather than merged away: FOX10 reported Johnson intended to appeal. The verified fact is that the sanction was imposed on October 10, 2025 in the terms quoted, not that it will survive appellate review. If the order is later vacated or modified, this file is amended.

Related case files

• United States v. Hayes: a federal defender sanctioned $1,500 for a fictitious citation, where the court declined to find AI use — the closest comparator inside the federal-defender system.
• Whiting v. City of Athens: the Sixth Circuit imposes $15,000 punitive sanctions on each attorney for fake citations — appellate-level escalation of the same conduct.
• Johnson v. Dunn: Butler Snow attorneys disqualified and referred over five hallucinated ChatGPT citations — the other Alabama federal case, where the sanction was disqualification rather than a fine.

Sources

Cited in this case file. Tier 1 = primary court record; Tier 2 = independent press. Each figure was checked against the live source on 2026-08-14.

1. United States v. McGee, Nos. 1:24-cr-112-TFM / 1:24-cr-113-TFM (S.D. Ala., Oct. 10, 2025), Memorandum Opinion and Order on Sanctions, Moorer, J. (Tier 1, primary order, full text PDF). https://websitedc.s3.amazonaws.com/documents/USA_v._McGee_10_OCtober_2025.pdf
2. United States v. McGee (2025), full-text reprint of the sanctions order (Tier 1, primary order as republished by FindLaw). https://caselaw.findlaw.com/court/us-dis-crt-s-d-ala-sou-div/117821752.html
3. Bloomberg Law, Jennifer Kay, “Fake AI Citations Produce Fines for California, Alabama Lawyers,” 2025-10-13 (Tier 2, independent press). https://news.bloomberglaw.com/litigation/fake-ai-citations-produce-fines-for-california-alabama-lawyers
4. FOX10 News / WALA-TV (Mobile), “‘It is just wrong’ – federal judge fines, chastises Loxley lawyer for AI snafu,” 2025-10-13 (Tier 2, independent press; carries the appeal statement). https://www.fox10tv.com/2025/10/13/it-is-just-wrong-federal-judge-fines-chastises-loxley-lawyer-ai-snafu/
5. 1819 News, “‘Just wrong’: Baldwin County lawyer fined, reprimanded by federal judge after using AI to create draft court filings,” 2025 (Tier 2, independent press). https://1819news.com/news/item/just-wrong-alabama-lawyer-fined-reprimanded-by-federal-judge-after-using-ai-to-create-draft-court-filings
6. FOX10 News / WALA-TV (Mobile), “Lawyer in Mobile ‘kingpin’ case admits using AI program that produced ‘nonexistent’ citations,” 2025-07-16 (Tier 2, independent press; contemporaneous with the defendant’s request for new counsel). https://www.fox10tv.com/2025/07/16/lawyer-mobile-kingpin-case-admits-using-ai-program-that-produced-nonexistent-citations/