Four Lawyers Reportedly Sanctioned After Purportedly AI-Related Hallucinated Citations Appeared in Withers v. City of Aberdeen

In a breach of contract case in Mississippi, four lawyers were sanctioned and removed from the proceedings after submitting court filings that included hallucinated legal citations generated by AI tools. The presiding judge noted that the attorneys failed to verify the accuracy of the AI-generated content, violating civil procedure rules. The incident highlights the ongoing challenges regarding the use of generative AI in legal research and documentation.

In Withers v. City of Aberdeen, a federal judge in Mississippi reportedly sanctioned four lawyers after filings from both sides contained purportedly hallucinated legal citations linked to unverified AI use. The court said Kathleen Wilson used First Drafts to draft a filing and Kathryn Williams used an AI legal-research tool; all four attorneys were removed from the case and fined.

Source: AI Incident Database

Risk classification

  • Primary risk domain: 3 Misinformation
  • Primary risk subdomain: 3.1 False or misleading information

The AI systems generated fabricated legal citations (hallucinations) which were submitted as factual evidence in court filings, misleading the court.

Additional risk subdomains

  • 5.1 Overreliance and unsafe use: The lawyers blindly relied on the AI-generated citations without verifying their authenticity, leading to professional sanctions.

Causal factors

  • Entity: AI
  • Intent: Unintentional
  • Timing: Post-deployment

The incident was caused by the AI system generating hallucinated citations, which was an unexpected and unintentional outcome of its deployment.

EU AI Act risk tier

  • Risk tier: 3 Limited Risk

Risk Level 3: Limited Risk. The AI systems involved are drafting and research assistants that generate text, falling under transparency obligations for AI-generated content.

AI system and alleged parties

  • AI system: AI legal-research tool
  • AI purpose: Writing Assistant; Technical Text Generation
  • Behaviour type: Assistant
  • Alleged developer: Large language model developers, First Drafts, AI legal research tool developers
  • Alleged deployer: Shauncey Hunter Ridgeway, Mark McClinton, Lawyers, Kathryn Y. Williams, Kathleen M. Wilson
  • Alleged harmed parties: Tom Withers III, Judicial integrity, Epistemic integrity, City of Aberdeen, Mississippi

Harm severity

Severity ratings are based on this scale.

Highest direct severity in any category: Minor. Severity is scored from Negligible to Catastrophic in each harm category, for harm the reports describe as caused directly or indirectly by the AI system.

  • Physical: direct Negligible, indirect Negligible
  • Infrastructure: direct Negligible, indirect Negligible
  • Property: direct Negligible, indirect Negligible
  • Financial: direct Negligible, indirect Negligible
  • Environmental: direct Negligible, indirect Negligible
  • Malicious content: direct Negligible, indirect Negligible
  • Differential treatment: direct Negligible, indirect Negligible
  • Civil rights: direct Negligible, indirect Negligible
  • Democracy: direct Negligible, indirect Negligible
  • Privacy: direct Negligible, indirect Negligible
  • Psychological: direct Negligible, indirect Negligible
  • Epistemic: direct Minor, indirect Negligible
  • Child sexual exploitation and abuse: direct Negligible, indirect Negligible

Epistemic

Reported: The report explicitly describes epistemic harm in the form of fabricated legal citations generated by AI.

Directly caused: The AI tools generated multiple nonexistent legal cases (hallucinations) which were then presented as factual in court filings.

People affected

  • Occurrences reported: 1
  • People reportedly harmed: 4
  • People reportedly exposed: 6

Potential causes

Management

  • Absence of AI Policy: Solo practice lacked guidelines or policies for AI tool usage.
  • Disregard of Policy: Firm partner ignored existing policy requiring verification of research.

Technology

  • AI Hallucinations: AI-powered program generated nonexistent legal citations.
  • Limited Data Scope: In-house tool lacked Mississippi law but was used for research.

Data Inputs

  • Incomplete Training Data: AI models lacked access to verified, up-to-date regional case law.

Human Factors

  • Ignorance of AI Risks: Attorney did not know that generative AI could produce fake citations.
  • Blind Reliance on AI: Attorneys trusted AI outputs without performing manual verification.

Process and Methods

  • No Verification Step: Attorneys failed to check the authenticity of citations before filing.

Regulatory Environment

  • Rule 11 Violation: Attorneys certified false information as factual in court filings.

Information quality

  • Classification confidence: High
  • Reason for confidence: The report provides clear, detailed, and uncontradicted facts about the lawyers, the specific AI tools used, the sanctions imposed by the judge, and the nature of the AI hallucinations.

Four lawyers in Mississippi were sanctioned for submitting AI-generated fake legal citations in a civil lawsuit. The incident represents a professional misconduct and technology integration issue with negligible national security implications.

  • Overall national security impact: Negligible
  • Scope: Single nation
  • Primary target: United States
  • Alleged perpetrator: Individual

Threat characteristics

  • Imminence: Long-term. The issue represents a long-term professional standards and AI integration challenge rather than an imminent national security threat.
  • Autonomy: Human-controlled. The AI tools acted as drafting assistants, and humans retained final control and responsibility over submitting the court documents.
  • Novelty: Established threat. AI hallucinations in legal filings have occurred in several previous high-profile cases, making this an established issue.

Impact by dimension

  • Physical security: Negligible. No physical systems, infrastructure, or human safety were impacted or threatened by this incident.
  • Information security: Negligible. The incident involves negligent use of AI in a civil court filing, with no connection to intelligence compromise or state-sponsored disinformation.
  • Sovereignty: Negligible. While court proceedings were temporarily disrupted, this was a routine civil case resolved standardly under Rule 11, posing no threat to state authority.
  • Economic security: Negligible. There was no threat to strategic industries, financial systems, or national technological competitiveness, only minor personal fines for the lawyers.
  • Societal stability: Negligible. The incident did not involve mass surveillance, systematic discrimination, or any threats to societal stability or civil liberties.
Explore in the interactive Incident Tracker