Case D-54 · AI Sanctions Case Tracker

In re Stephen Aarons (Sandoval murder appeal)

New Mexico Supreme Court, No. S-1-SC-40845, Dispositional Order of Direct Contempt entered September 9, 2026

Episode 1

“[D]emonstrated a lack of remorse and a lack of concern for his client.”

The contempt panel, on attorney Stephen Aarons, in In re Stephen Aarons (Sandoval murder appeal)

The case

This is the tracker entry where the AI did not invent citations. It invented evidence. Aarons took over a murder appeal and filed a ChatGPT summary of the trial record without reading it, and the summary contained witnesses who do not exist and testimony nobody ever gave. It is also the case that ended "I didn't know AI makes things up" as a defense: the New Mexico Supreme Court treated claimed ignorance of the hallucination problem as inexcusable in 2026, and answered with its contempt power instead of an ordinary sanction.

What happened

After agreeing to take over Oscar Sandoval's appeal, Santa Fe attorney Stephen Aarons, in practice for more than 40 years, had ChatGPT summarize the trial proceedings and filed the result without proofreading. The filing presented fabricated police testimony and entirely fictional witnesses, down to invented detail about what the shooter wore and statements falsely credited to a real witness. He never told his client: not about the AI use, not about the invented testimony, not even about the court's order to appear in person and explain himself.

The rule and the sanction

Acting under its inherent superintending authority, the court held Aarons in direct contempt. He was ordered to pay $5,000 to the State Bar of New Mexico Client Protection Fund within 30 days and referred to the disciplinary board for investigation. The court struck every page of his briefing, barred him from appearing before it until the discipline case resolves, and appointed the public defender to take over the appeal.

How it could have been avoided

Never outsource the record. A summarizer can invent witnesses and testimony, not just citations, and in a criminal appeal the client's liberty pays for the shortcut. Read the transcript yourself, check every attributed statement against its page and line, and tell your client what happened before the court has to.

Watch the episode

This case is covered in Episode 1: Lawyer Sanctioned for Fake AI Cases in Murder Appeal (Ep 1) (watch on YouTube).