Georgia Supreme Court suspends prosecutor over fake AI-generated citations

The Georgia Supreme Court imposed a six-month ban on Clayton County assistant district attorney Deborah Leslie after finding that artificial-intelligence tools helped produce fake and misleading citations in a murder case ruling. The court also ordered Leslie to complete additional training in ethics, brief writing and proper AI use, signaling that unverified generative output is now a courtroom discipline issue, not a clerical mistake.

The sanctions stem from Payne v. The State, docket S26A0459, a case involving Hannah Payne, who was convicted in December 2023 and later sought a new trial. During oral argument on March 18, 2026, held at 10 a.m. at the Nathan Deal Judicial Center in Atlanta, Justice Nels S.D. Peterson questioned Leslie about citations that did not appear to be real. Two days later, the court ordered the state to explain how the trial court’s September 12, 2025 order denying Payne’s motion for new trial came to include nine case citations that either did not exist or did not support the propositions for which they were cited.

Justice Benjamin Land wrote in the opinion issued May 5, 2026, that citing cases that do not exist or do not support the point being made violates the court’s rules and falls well below what Georgia lawyers are expected to do. The Supreme Court vacated the earlier order and sent the matter back for a new ruling without the fictitious citations, forcing the appeal to be reconsidered on a clean record.

The episode reached beyond one bad filing because the trial judge had adopted much of Leslie’s proposed order, including the fabricated citations, in denying the new-trial request. Clayton County District Attorney Tasha Mosley later apologized to Chief Justice Michael P. Boggs after the problem came to light, underscoring the institutional fallout when AI-generated language is inserted into a judicial order without independent verification.

The case lands in a judiciary that had already begun studying the technology. On October 22, 2024, the Georgia Supreme Court created an Ad Hoc Committee on Artificial Intelligence and the Courts, chaired by Justice Andrew A. Pinson and formed with the National Center for State Courts to assess the risks and benefits of generative AI. In Payne, those risks moved from policy discussion into appellate record and due-process territory, where a flawed citation trail can force higher courts to unwind part of a criminal proceeding.