Case D-33 · AI Sanctions Case Tracker

Laurie Ibach and Mark Stewart v. Bruce Stewart

Supreme Court of Alabama, opinion released April 24, 2026

Episode 18

The case

The promise case. In a footnote in his reply brief, appellate lawyer W. Perry Hall told the Alabama Supreme Court that "the mistake will not recur." The second and third citations after that sentence were to cases that do not exist. The court counted, dismissed the entire appeal as a sanction, and wrote the episode's rule in its disposition: on appeal, fabricated authority is a defect in the appeal itself, and the client pays for it alongside the lawyer.

What happened

Hall's opening and reply briefs in a Mobile family trust dispute contained numerous nonexistent, invalid, inaccurate, irrelevant, and misquoted authorities produced through an AI research tool. Opposing counsel took the opening brief apart citation by citation and told the court some authorities had "no record, opinion, or other indication" of existing. The reply brief answered in a single footnote, blamed a first use of an AI research tool, accepted responsibility, and then cited more bad authority, including a case already flagged as nonexistent, four more times.

The rule and the sanction

The appeal was dismissed. Hall was assessed $17,200 in fees and costs, referred to the Alabama State Bar for possible discipline, and barred from filing anything further in that court unless a lawyer in good standing co-signs. Before the sanctions hearing he had admitted the authorities did not exist, apologized, reported himself to the Bar, and reimbursed the other side; the court found him remorseful and imposed the full package anyway, calling the misuse "widespread and particularly egregious."

How it could have been avoided

The moment the other side flags a citation, the next filing is a new decision, not a continuation. Say the flag is right if it is, pull the bad authorities, and file nothing more until the brief is clean. A promise to a court is a statement of fact; read the next sentence of your own brief before you make one.

Watch the episode

This case is covered in Episode 18: "The Mistake Will Not Recur": Two Citations Later, It Did (Ep 18) (watch on YouTube).

Sources