ChatGPT Brief Collapses, Leaving a Murder Appeal in Limbo

ChatGPT Brief Collapses, Leaving a Murder Appeal in Limbo
Stephen Aarons took on the appeal of Oscar Renee Sandoval’s murder conviction in March 2025, after Sandoval was sentenced to life in prison for killing his partner, Shiereen Al-Jibury. Aarons later said he used ChatGPT to summarize trial materials, believing it would produce a “bulletproof summary of proceedings.”

In August 2025, he filed the appeal brief. It did not merely contain sloppy phrasing: the New Mexico Supreme Court found that it included testimony attributed to witnesses who did not exist, fabricated police testimony, incorrect descriptions of the shooter’s appearance and misrepresented legal authority. Aarons acknowledged that he had not verified the AI-generated factual claims or legal citations before signing the filing.

The state moved weeks later to strike parts of the brief. At an August 21 hearing, Aarons accepted responsibility, telling the justices, “It’s of little comfort to know that my stupidity is what brings us together this afternoon.” He maintained that he had not known AI could invent facts and later described the failure as an “honest mistake.”

The justices were unmoved by the attempt to frame the case chiefly as a technology problem. Justice C. Shannon Bacon said ignorance of AI hallucinations was no defense, asking whether Aarons followed the news and warning that lawyers’ reliance on fabricated AI material had become “an above-the-fold story every single day.” Her larger point was simpler: an attorney’s duty to verify a brief does not change because the unreliable work came from software rather than a junior lawyer.

On Wednesday, the court held Aarons in direct contempt, imposed a $5,000 fine and referred him to disciplinary authorities. It also barred him from appearing before the court pending that process, wiped the defective briefs from the record and ordered new counsel for Sandoval. The appeal will now proceed in the 2026–27 term—delay that the court stressed falls most heavily on the incarcerated client, not the lawyer who filed the false material.

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