Johnson v. Dunn

Two discovery motions contained five problematic authorities supplied by ChatGPT, including nonexistent cases and citations to real decisions that did not support the propositions stated. Multiple lawyers signed the filed documents. The drafting attorney used ChatGPT to identify supporting authority and inserted the results without verification. The reviewing attorney signed and filed the motions without checking the additions. The supervising partner and designated deputy attorney general allowed his signature to appear without reviewing the motions. The incarcerated plaintiff identified the problems, prompting the court’s investigation and show-cause proceeding.

Rule 11 did not apply because the filings were discovery motions, so the court relied on its inherent authority. “Fabricating legal authority is serious misconduct that demands a serious sanction,” the court wrote. It publicly reprimanded Reeves, Cranford, and Lunsford; disqualified them from the case; ordered broad notice to clients, opposing counsel, judges, and licensing authorities; and imposed no monetary penalty. The court released two uninvolved attorneys and Butler Snow from the disciplinary proceeding without sanction.