When AI Writes Your Apology for Using AI

On April 24, 2026, the Supreme Court of Alabama dismissed an appeal because the appellants' briefs were so full of fabricated and nonexistent case citations that the court found nothing left to review.

The attorney, W. Perry Hall, had used generative AI to research and support his arguments. Opposing counsel caught the hallucinations and documented them in the appellee's brief. Hall acknowledged the problem in a reply brief footnote, apologized, and promised: "The mistake will not recur." The very next sentence in that footnote cited two more cases that do not exist. (Ibach v. Stewart, SC-2025-0106, Ala. Apr. 24, 2026, at 14.)

Justice Cook, concurring, offered the uncomfortable observation: it is "hard to imagine how this could occur absent, perhaps, using AI to craft the apology for having used AI." (Id. at 40 (Cook, J., concurring specially).)

What the court imposed

Hall was ordered to pay $17,200 in attorney fees and costs to opposing counsel, pay double costs of the appeal to the court, and submit any future filings before the Alabama Supreme Court with a co-signature from a bar-member attorney in good standing. The court also referred him to the Alabama State Bar for potential disciplinary proceedings.

His clients lost their appeal. Not because their underlying claims were meritless, but because their attorney could not give the court a single reliable citation to support them. (Id. at 33–36.)

Where the court placed the blame

The majority was careful on this point. Generative AI, the court explained, can be a useful research tool. The problem is not the technology. "The root of the problem," the court wrote, is "attorneys failing to properly research and verify the results of AI-generated citations, in short, attorney negligence in checking his or her work." (Id. at 30.)

Justice Cook pointed to Rule 1.1 as the governing framework. Technology competence is part of competence. The obligation to verify is not new; AI just makes it easier to skip. (Id. at 40 n.6 (Cook, J., concurring specially).)

What was missing

Hall had no contemporaneous record showing he had independently verified any of the citations in his briefs. When the court demanded accountability, there was nothing to produce.

A documented verification process, one that creates an attorney-signed record of which AI-generated content was independently confirmed and when, is what was absent here. That record does not verify citations for you. It documents that you did. The distinction is the difference between an attorney who can stand behind their work and one who cannot.

The Alabama Supreme Court is not alone. The opinion cited parallel sanctions from the Northern District of Alabama, the Southern District of Alabama, and the Sixth Circuit, all issued in 2025 and 2026. (Id. at 29–30.) Orthodoxy was built to create the record that exists when a court asks for one.