The New Mexico Supreme Court has taken a hard line against artificial intelligence negligence, holding attorney Stephen Aarons in direct contempt of court. The sanction stems from a brief Aarons filed in August 2025 that contained testimony from witnesses who never existed. Among the fabricated sources were “Officer Michelle Amarillo” and “Teresa Marquez,” characters conjured by a large language model rather than recalled from case records. This isn’t just a clerical error; it is a fundamental breach of legal ethics that jeopardized the appeal of Oscar Renee Sandoval, a man serving a life sentence for murder.
Aarons, a criminal defense lawyer with over four decades of experience, admitted he fed trial transcripts into ChatGPT to draft the document. He signed and filed the brief without verifying a single factual claim or legal citation. When the state moved to strike the misleading portions weeks later, the damage was already done. The court’s order highlights a disturbing lack of diligence, noting that Aarons failed to inform his client about the misrepresentations. The justices concluded he demonstrated “a lack of remorse and a lack of concern for his client,” referring him to the disciplinary board for further proceedings.
This case serves as a stark warning to the legal profession: AI is a tool, not a substitute for professional judgment. While many firms are integrating generative models to speed up research, the duty of candor to the tribunal remains absolute. Aarons’ mistake wasn’t using the technology; it was abdicating his responsibility to validate its output. The hallucinations included fake quotes from Danny and Linda Stanton regarding threats, as well as fabricated details about the shooter’s clothing. These weren’t minor typos. They were complete inventions that could have derailed justice.
The ruling underscores a growing tension between efficiency and accuracy in law. As models become more persuasive, the risk of subtle fabrication increases. Judges are no longer amused by excuses involving new technology. They expect lawyers to know the difference between a real precedent and a digital mirage. With Sandoval’s conviction standing firm, the focus now shifts to whether Aarons will lose his license entirely. The message is clear: if you can’t verify it, don’t file it.
