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Alabama DOC Attorneys Reprimanded for 
Filing AI-Written Briefs in Prisoner’s Suit

The federal court for the Northern District of Alabama issued an order on May 16, 2025, demanding that attorneys representing the state Department of Corrections (DOC) show cause why they should not be sanctioned for filing error-riddled briefs apparently written by an artificial intelligence (AI) software program.

AI programs are widely used by internet search engines like Google to summarize search results for users. But they are not infallible, frequently unable to discern whether a “hit” from a search term actually applies to the request. That’s bad enough when you’re trying to decide if your county zoning code will allow you to build a backyard deck and the AI returns an answer from a different municipality. But beyond that sort of error, the technology is also known for “hallucinations”—lies, made up out of whole cloth in response to a query. It goes without saying that AI should not be used to file legal briefs. 

In this case, state prisoner Frankie Johnson had accused DOC officials of failing to protect him from repeated assaults in its notoriously violent prisons. Attorneys representing the prison system filed a motion for leave to depose Johnson. The response filed by one of his attorneys with Norton Rose Fulbright U.S. LLP in Houston, Jamilah S. Mensah, pointed out that at least five case citations provided in support of the motion were either wrong or didn’t exist. One was to a traffic court case from 1939. 

An irked U.S. District Judge Anna Manasco went on a search for the allegedly fabricated citations “to no avail,” she wrote in her show-cause order to the DOC attorneys. Among those lawyers was Bill Lunsford with Butler Snow in Huntsville, who has billed the prison agency for so much work that Rep. Chris England (D-Tuscaloosa), who sits on the state legislature’s contract review committee, called him “basically a government agency at this point.”

The judge’s ire was apparently lost on Lunsford; despite collecting $42 million to defend the DOC since 2020, he attempted to brush off attending the show-cause hearing. After Judge Manasco shut down that attempt and then humiliated him at the hearing, DOC attorneys filed a corrected motion for leave to compel Johnson’s deposition. The case remains pending, and PLN will update further developments as they unfold. See: Johnson v. Dunn, USDC (N.D. Ala.), Case No. 2:21-cv-01701.  

 

Additional source: Birmingham News

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Related legal case

Johnson v. Dunn