Case D-46 · AI Sanctions Case Tracker

Hannah Payne v. State

Supreme Court of Georgia, opinion decided May 5, 2026

Episode 9

The case

The fabrications did not stay in the lawyer's own filings. Prosecutor Deborah Leslie's AI-generated citations infected a trial court's order, because the judge had asked her to draft it. The Supreme Court of Georgia vacated that order along with sanctioning her, which makes this the tracker case for a quiet systemic risk: AI errors that reach a signed judicial order stop being one lawyer's problem.

What happened

Leslie, a Clayton County Assistant District Attorney, repeatedly filed appellate documents in the Hannah Payne murder-case appeal carrying AI-generated citations: at least five to cases that do not exist and at least five more that did not support the propositions asserted. She first claimed the filing had been altered, then admitted using AI. The same errors appeared in the trial court's order denying the new-trial motion, which the judge had asked her to draft.

The rule and the sanction

The court held that citing nonexistent cases, or cases that do not support the proposition, "falls far beneath the conduct we expect from Georgia lawyers." Leslie and the Clayton County District Attorney's Office were formally admonished. Leslie was suspended from practicing before the Supreme Court of Georgia for six months, conditioned on completing 12 hours of CLE on the proper use of AI. The tainted order was vacated and remanded, with the trial court directed to issue its own order containing no fictitious or misattributed citations.

How it could have been avoided

Verify every authority before it reaches an appellate court; a state's highest court treats AI fabrications as an institutional integrity problem, not a typo. And never let AI draft an order a judge will sign. When the judge's own order carries the errors, the order itself falls.

Watch the episode

This case is covered in Episode 9: Fake AI Cases Ended Up in a Judge's Order (watch on YouTube).