Lawyer Held in Contempt Over ChatGPT Fake Witnesses
New Mexico's Supreme Court held lawyer Stephen Aarons in contempt for citing fake testimony from fabricated witnesses in a ChatGPT-generated brief.
ChatGPT fake witnesses have now cost a veteran New Mexico defense attorney his standing before the state's highest court. The New Mexico Supreme Court held lawyer Stephen Aarons in direct contempt for filing a brief that quoted testimony from people who never existed, and the fallout is still unfolding for the client he was hired to defend.
What Aarons Actually Filed
The order came down on a Wednesday, and it did not mince words. Aarons, a criminal defense attorney with more than four decades of practice in New Mexico, submitted a brief in chief that the court said contained "false testimony from wholly fabricated witnesses." The names attached to that invented testimony were Officer Michelle Amarillo, Officer Sanchez, Manal Al-Jibury, and Teresa Marquez.
Those were not the only fictions. Aarons also admitted to submitting false testimony from Danny Stanton claiming he received threats, false testimony from Linda Stanton about threats her husband supposedly received, and false testimony from Mariah Chavez and a fabricated Teresa Marquez about the shooter's clothing and appearance. His citations to prior cases were real, but he described them inaccurately.
The brief went to the court in August 2025. Weeks later, the state of New Mexico moved to strike portions of it.
How the ChatGPT fake witnesses Got Into the Brief
The mechanics matter here, because they explain how a lawyer with forty years of experience ends up quoting people who were never called at trial. Aarons told the court he started with Rev.com, a service that produces AI transcripts of audio files, then fed that transcript and other case materials into ChatGPT. The records he loaded included the record proper, the statement of issues, and some of the discovery.
He said he believed he'd confirmed the trial transcript was accurate before running it through the tool. The transcript wasn't the problem. That's what he says. But when he loaded everything else alongside it, something happened, and by his own account that something, the thing that occurred once all the other material sat next to the transcript inside the tool, was where the real trouble actually lived.
Aarons told the court he used a version of ChatGPT powered by the OpenAI o3 model, released earlier in 2025. He assumed it would generate a reliable summary. "I assumed that it generated a bulletproof summary of proceedings," he said at an August 21 hearing. And he explained he trusted the output because AI use is so widespread in legal and medical fields, a fact he said made the tool's answers feel like something he and others across both professions could rely on without question.
Then he signed the brief.
The Justices Were Not Sympathetic
Justice C. Shannon Bacon delivered the sharpest rebuke. She told Aarons there were "at least eight or nine provisions in the code of conduct that you violated." She said she was struggling with his claim of ignorance about AI hallucinations, pointing out that both her 13-year-old nephew and her 75-year-old stepmother understand the problem.
"So either you buried your head in the sand;and that's a choice to do that, an intentional choice to be uninformed,or you took a gamble, and neither of those are consistent with the code of conduct."
Aarons offered that he filed the brief a year earlier and much had come out since. Bacon was unmoved. She told him there is no material distinction between citing a fake case and misdescribing a real one, because the rules on candor to the court apply with equal force either way.
Chief Justice Julie Vargas focused on the human cost. She told Aarons she cared less about policy proposals and more about the defendant sitting in custody while the matter gets resolved.
Justice Michael Vigil made the simplest version of the argument. The tool does not matter, he said, and neither does its sophistication. "It doesn't matter whether you use a C-student lawyer or a A-student lawyer [if] you didn't check their work before you filed the brief," he said. "That's the issue."
Who Is Actually Paying for This
The defendant is Oscar Renee Sandoval, convicted of killing Shiereen Al-Jibury, his partner and the mother of his children. He was sentenced to life in prison in February 2025. His family hired Aarons to handle the appeal.

Sandoval learned nothing about the ChatGPT fake witnesses from his own lawyer. Nothing at all. And when Bacon asked whether he had told his client, Aarons said he had not, citing the language barrier that he claimed stood between them. "He's a Spanish speaker and I wanted to see what happened today," Aarons said.
He told Sandoval's brother and cousin there was a problem with the brief. He didn't say what kind. "I didn't talk about ChatGPT," Aarons said. And he didn't tell them anything more than that, because what he actually said to them, in his own words, was simply that there was a problem with the brief that he filed, and that's all he offered. "I just said there was a problem with the brief that I filed.
Bacon pressed the point. Sandoval needed to know the full extent so he could decide whether Aarons was the right person to represent him. She also asked whether Aarons was working on a public defender contract or as private counsel. Private counsel, he answered. He had not been paid yet. "I'm not sure that's going to happen," Bacon replied.
The Penalty and What Happens Next
The court fined Aarons $5,000. That money goes to the State Bar of New Mexico Client Protection Fund. And he can't appear before the New Mexico Supreme Court while disciplinary proceedings play out, a restriction the court attached to its ruling after reviewing what it described as his conduct in the matter. It referred him to a disciplinary board. The board will weigh his case. It noted he "demonstrated a lack of remorse and a lack of concern for his client.
More penalties could follow from that investigation. The court also struck all previous briefs from the record and ordered the public defender office to appoint new counsel for Sandoval. The case will proceed in the court's 2026-27 term.
- $5,000 fine paid to the State Bar of New Mexico Client Protection Fund
- Barred from appearing before the New Mexico Supreme Court pending discipline
- Referred to a disciplinary board for further proceedings
- All prior briefs struck from the record
- New counsel ordered for the defendant
Aarons suggested the court issue a standing order requiring briefs to carry a certificate of compliance regarding AI use. The justices treated that as a distraction. Bacon told him that if he had relied on a first-year associate who made things up, he would be in the same position.
Aarons spoke after the hearing. He wrote the brief himself, he said, but the table of contents and summary contained numerous errors, a detail he offered in a statement that also touched on what he didn't know at the time about how AI can hallucinate facts. It's an honest mistake, he said. And he hopes the disciplinary board weighs that. He said, "It is a lesson learned for all professionals who rely upon this powerful but sometimes unstable technology.
Whether the board sees it that way is another matter. The court already answered the broader question about verification, and it did so without much patience for the idea that a lawyer can outsource judgment to a tool and still sign the page. For Sandoval, the practical result is a year of lost time, a new lawyer, and a case that starts over in 2026.
Frequently Asked Questions
Who was the New Mexico defense attorney held in contempt, and what did the court say his brief contained?
The New Mexico Supreme Court held lawyer Stephen Aarons in direct contempt. The court said his brief in chief contained "false testimony from wholly fabricated witnesses."
Which fabricated witnesses and false testimonies did Aarons admit to submitting?
The invented testimony was attributed to Officer Michelle Amarillo, Officer Sanchez, Manal Al-Jibury, and Teresa Marquez. Aarons also admitted to submitting false testimony from Danny Stanton claiming he received threats, from Linda Stanton about threats her husband supposedly received, and from Mariah Chavez and a fabricated Teresa Marquez about the shooter's clothing and appearance.
How did the ChatGPT fake witnesses end up in the brief, according to Aarons?
Aarons said he started with Rev.com, an AI transcription service, then fed that transcript and other case materials, including the record proper, statement of issues, and some discovery, into ChatGPT. He told the court he used a version powered by the OpenAI o3 model and assumed it would generate a reliable summary, saying he "assumed that it generated a bulletproof summary of proceedings."
What penalties did the court impose on Aarons, and what happens next in the case?
The court fined Aarons $5,000, payable to the State Bar of New Mexico Client Protection Fund, and barred him from appearing before the New Mexico Supreme Court while disciplinary proceedings play out. It referred him to a disciplinary board, struck all previous briefs from the record, and ordered the public defender office to appoint new counsel for Sandoval, with the case proceeding in the 2026-27 term.
Who is the defendant in the case, and did he learn about the ChatGPT fake witnesses from his lawyer?
The defendant is Oscar Renee Sandoval, convicted of killing Shiereen Al-Jibury, his partner and the mother of his children, and sentenced to life in prison in February 2025. Sandoval learned nothing about the ChatGPT fake witnesses from his own lawyer; Aarons told the court he had not told his client, citing a language barrier.
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