SANTA FE — Aarons is a private attorney based in Santa Fe, New Mexico. He was handling the appeal of Oscar Renee Sandoval, who was convicted and sentenced to life in prison for murder. Sandoval pleaded not guilty to the murder of the mother of his children before being convicted.

Justice C. Shannon Bacon questioned Aarons during the hearing regarding his awareness of current events. "Counsel, do you watch the news? Do you listen to the radio? Do you read anything about what's going on in the world?" Bacon asked.

She added, "Because the problem with lawyers relying on AI hallucinations is an above-the-fold story every single day." He said in a statement that he used ChatGPT to summarize trial proceedings and did not understand the degree to which AI could hallucinate facts. "I am remorseful but hopeful that the disciplinary board takes into account it was an honest mistake," he said. He described the incident as a lesson learned for all professionals who rely upon this powerful but sometimes unstable technology.

The appeal was assigned to New Mexico public defender Kim Chavez Cook on September 2, 2026. Cook declined to comment on the matter.

Timeline

On August 10, 2026, the New Mexico Supreme Court ordered Aarons to explain how fabricated material, including fictional statements that the shooter was wearing dark pants and a white shirt, was included in his brief. On August 21, 2026, Stephen Aarons told the court at an August 21 hearing that he fed a computer-generated transcript and other case materials to ChatGPT, presuming it would generate a bulletproof summary. During that same hearing, Justice C. Shannon Bacon asked, "Counsel, do you watch the news? Do you listen to the radio? Do you read anything about what's going on in the world?" Bacon noted that "Because the problem with lawyers relying on AI hallucinations is an above-the-fold story every single day."

On September 10, 2026, the New Mexico Supreme Court fined attorney Stephen Aarons $5,000 and held him in contempt for failing to verify the accuracy of a court filing. On that same date, the New Mexico Supreme Court stated that Aarons' filing contained false testimony from wholly fabricated witnesses generated by OpenAI's ChatGPT. Also on September 10, 2026, the New Mexico Supreme Court said it will refer Stephen Aarons to an attorney disciplinary board for investigation.

Why It Matters

The ruling shows the risks associated with attorneys using generative artificial intelligence without verifying the output. The New Mexico Supreme Court emphasized that Aarons demonstrated a lack of remorse and concern for his client while noting that stories about AI hallucinations are prevalent. The court's decision to refer Aarons to an attorney disciplinary board reflects the seriousness with which the judiciary views the submission of fabricated evidence.

This case occurs within a broader context where dozens of lawyers have been sanctioned for filing briefs where AI made up case citations or misquoted the law. Aarons attributed the error to a misunderstanding of AI capabilities, stating he did not understand the degree to which the technology could hallucinate facts. The referral to the disciplinary board leaves open questions regarding what specific actions will be taken and how this ruling might influence future guidelines for attorneys using such tools.