New Mexico Lawyer Fined $5,000 After Using ChatGPT to Draft Murder Appeal With Fake Witnesses
A New Mexico defense lawyer has been fined $5,000 after using ChatGPT to help draft a murder appeal, failing to check what it produced and filing a brief that included four witnesses who never existed, false testimony, and misrepresented legal authority.
The New Mexico Supreme Court held Santa Fe attorney Stephen D. Aarons in direct contempt Wednesday over the brief he submitted for Oscar Renee Sandoval, who is appealing a first-degree murder conviction and life sentence. Aarons admitted he had not verified the AI-generated factual claims or legal authorities before signing and filing the document.
According to the court's September 9 order, ChatGPT produced testimony from people identified as Officer Michelle Amarillo, Officer Sanchez, Manal Al-Jibury and Teresa Marquez. None had provided the testimony attributed to them, and the court described all four as fabricated witnesses. Two were presented as police officers.
The brief also put false statements in the mouths of people who had actually testified. It incorrectly said Danny Stanton received threats from Sandoval, attributed testimony about those threats to Linda Stanton that she had not given, and misstated what witnesses said about the shooter's clothing and appearance.
The problems extended to the legal arguments. The filing also misrepresented authority from two New Mexico cases.
Aarons told the justices during an August 21 hearing that he had uploaded a computer-generated trial transcript and other case materials to ChatGPT while preparing Sandoval's appeal. He expected the program to produce what he called a "bulletproof summary."
Instead, Aarons acknowledged relying on the output without checking it closely enough against the case record before submitting the brief to New Mexico's highest court.
Justice C. Shannon Bacon challenged his explanation that he had not understood how extensively generative AI could produce false information, pointing to the widely reported problems involving lawyers who have submitted unverified AI-generated material in court.
Aarons also failed to tell Sandoval that the brief contained factual and legal misrepresentations or that he had not verified the material before filing it. According to the order, he did not inform his client about the proceedings that followed after the Supreme Court ordered him to explain what had happened.
The justices concluded that Aarons had demonstrated "a lack of remorse and a lack of concern for his client."
Aarons later described the episode as an honest mistake and said he was remorseful. He said he hoped the disciplinary board would consider the circumstances and called the case a lesson for professionals using AI tools.
The filing was meant to challenge Sandoval's conviction for the murder of Shiereen Al-Jibury, the mother of his children.
A jury convicted Sandoval in January 2025 of first-degree murder and aggravated assault with a deadly weapon. Prosecutors said Al-Jibury ran toward a passing vehicle on April 1, 2024, and motioned for the driver to call 911 before Sandoval pursued and fatally attacked her.
Sandoval then threatened a witness and fled, according to the Doña Ana County District Attorney's Office. He was later apprehended in Mexico.
A judge sentenced him in February 2025 to life in prison for murder, plus another four and a half years for aggravated assault and a firearm enhancement.
The AI-generated errors have now wiped out the briefing filed on Sandoval's behalf. The Supreme Court struck every brief Aarons submitted and appointed the Law Office of the Public Defender to provide Sandoval with replacement counsel.
His appeal remains alive. Once a new attorney enters the case, the court will issue another briefing schedule and still intends to hear Sandoval's challenge during its 2026-2027 term.
Aarons was also barred from appearing before the New Mexico Supreme Court while disciplinary proceedings are pending and referred to the state's Disciplinary Board. The court may consider further action after that process concludes.
He must pay the $5,000 sanction to the State Bar of New Mexico Client Protection Fund within 30 days of the September 9 order.
