Courtrooms run on facts, testimony and citations that can withstand scrutiny — not phantom witnesses who never existed. Yet that's exactly what surfaced in a Santa Fe attorney's murder appeal, earning him a New Mexico Atty $5K fine from the state's highest court after he admitted leaning on generative AI to draft a legal brief riddled with invented details.

The Attorney Behind the Filing

Stephen Aarons, a solo practitioner based in Santa Fe, acknowledged in late August that he used ChatGPT to help write his initial brief appealing the February 2025 sentencing of client Oscar Renee Sandoval, who received life in prison plus 4.5 years following a first-degree murder conviction.

Fabrications Woven Into the Filing

The brief didn't just contain minor errors — it read more like a work of fiction dressed up as legal argument. According to the New Mexico Supreme Court's Wednesday decision, the document included testimony from police officers and other individuals who simply don't exist, along with false details about Sandoval's clothing and appearance. It also featured fabricated quotes describing threats supposedly made by Sandoval, plus legal citations that pointed to case law with no actual basis in reality.

Signed Without a Second Glance

Perhaps most damning, the court found Aarons never bothered to verify any of it before putting his name on the line. "Respondent admitted to the court that he did not verify the factual claims and legal authority in his AI-generated brief before signing it and filing it with the court, and that he did not inform his client of this failure or that the brief in chief contained multiple factual and legal misrepresentations," the court wrote — a two-fold failure that compounded the original mistake with a lack of transparency toward his own client.

The Court's Response Was Swift

Because Aarons demonstrated what the court described as "a lack of remorse and lack of concern for his client," combined with clear noncompliance with briefing requirements, the justices found him in direct contempt of court. The matter has now been referred to the state's disciplinary board for further review — a signal this fine is likely just the first consequence, not the last.

Barred From the Bench, For Now

Aarons was also barred from appearing before the high court while disciplinary proceedings play out, and a separate order requiring him to withdraw as counsel was issued Sept. 1. Wednesday's filing gave him 30 days to pay the $5,000 fine — a deadline that puts a firm timestamp on an otherwise open-ended disciplinary process.

Part of a Growing, Troubling Pattern

Aarons' case doesn't exist in isolation. As generative AI tools become more woven into everyday legal practice, the rate at which attorneys are being disciplined for misusing the technology has climbed sharply over the past year — like a slow leak turning into a steady drip nobody can ignore.

Echoes Across the Federal Courts

Earlier this month, the D.C. Circuit issued a rare sua sponte sanctions order after discovering nonexistent case citations in a brief filed by an attorney with McCabe Weisberg & Conway LLC, representing Deutsche Bank National Trust Co. in a foreclosure action. Around the same time, the Fifth Circuit questioned the validity of a court order blocking an anti-diversity Mississippi law, after finding it contained remarkably similar fabricated errors.

Aarons and a representative of the New Mexico Department of Justice weren't immediately available for comment Friday.

For a legal system built on the presumption that every citation, quote and witness can be traced back to something real, this case serves as a stark reminder — when technology fills in the blanks with fiction, the consequences land squarely on the humans who signed their names to it.