AI Errors in Murder Case Lead to Discipline for Georgia Prosecutor Over Fake Citations

Georgia Prosecutor Faces Sanction Over AI-Generated Errors in Murder Case

The Georgia Supreme Court issued a stern rebuke on Tuesday, disciplining a Georgia prosecutor for misusing artificial intelligence tools that led to fake and misleading case citations appearing in a murder case ruling. Deborah Leslie, a Clayton County assistant district attorney, was barred from appearing before the state's high court for six months and ordered to complete 12 additional hours of continuing legal education on ethics, brief writing, and proper AI use2

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The discipline for Georgia prosecutor came after the court found that "numerous fictitious or misattributed case citations" appeared in a lower court's 2025 order denying a murder defendant's bid for a new trial3

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. Justice Benjamin Land emphasized the severity of the misconduct, writing that "citing cases that do not exist or do not support the proposition for which they are cited is a violation of this Court's rules and falls far beneath the conduct we expect from Georgia lawyers".

How AI-Generated Content Infiltrated Legal Proceedings

The AI errors originated when Leslie prepared a proposed order urging the trial judge to deny Hannah Payne's request for a new trial. Leslie admitted to using artificial intelligence software to draft the briefs but acknowledged that the inaccurate case citations were not verified before submission to the court2

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. The trial judge adopted much of the proposed order, including the fabricated citations, in denying Payne's request, the Georgia Supreme Court said4

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Leslie apologized in an earlier court filing for failing to independently verify the AI-generated citations3

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. The sanction came in the appeal of Hannah Payne, who was sentenced to life in prison plus 13 years for the felony murder and false imprisonment of Kenneth Herring2

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. In May 2019, Payne witnessed a crash involving Herring and followed him despite 911 dispatchers instructing her not to engage. An altercation ensued, ending with Payne shooting Herring in the stomach, killing him2

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Vacated Ruling Opens Door for New Trial Assessment

The state justices vacated the earlier ruling and sent the case back to the trial judge, directing that a new order be issued without fictitious citations. Payne's lawyer, Andrew Fleischman, said in a statement: "Hannah Payne has strong issues for appeal. It is a shame that the State's misconduct is now delaying her opportunity to have those issues be decided"3

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Growing Pattern of Attorneys Failing to Vet AI Results

State and federal courts across the country have disciplined attorneys for using generative AI tools for legal research and drafting without vetting the results. The Georgia case is among the rarer instances involving a prosecutor's use of AI, and stands out because the lawyers' AI errors were repeated in a court opinion4

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. This incident highlights the risks of using generative AI in legal settings without proper oversight.

The state justices on Tuesday urged trial judges to review proposed orders "with the understanding that artificial intelligence software, with all of its potential risks and benefits, may have been used". This guidance signals a shift in how courts must approach legal ethics in an era where AI-generated errors can compromise the integrity of legal proceedings. The Clayton County District Attorney's Office did not immediately respond to requests for comment3

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