Court - Judge Name	Effective Date	Applicable To	Categories	Summary
Bankr. M.D. Ala. – Judge Christopher L. Hawkins	11/20/2025	Generative AI	Generative AI Usage	In In re Jackson Hosp. & Clinic, No. 25-30256-CLH, 2025 Bankr. LEXIS 3039 (Bankr. M.D. Ala. Nov. 20, 2025), the court issued an order for an attorney and her law firm (who were representing a creditor in a bankruptcy proceeding) to show cause why they should not be sanctioned for the repeated misuse of GenAI in court filings. Specifically, following the creditor’s filing of a related motion, the court observed that cited regulations “did not stand for the legal propositions” for which they were cited, noted that one attorney in particular had also previously cited caselaw that did not stand for the principle she cited it for, and pointed out that the party’s supporting briefs for a motion to reconsider the court’s decision also “continued to miscite authorities, and [the party’s supplemental brief] even recycled a fabricated quote” from another filing. In response to the court’s show cause order, the law firm conducted an investigation into the offending attorney’s other matters and concluded that she had also included a GenAI-created hallucination in a separate court filing. The attorney eventually admitted that she had “misled the Court” by previously denying the use of GenAI in connection with the filing, when in fact she “was aware [GenAI] was used by someone other than an associate at the Firm.” The court cited Alabama Ethics Rules 1.1, 3.1, and 3.3, 28 U.S.C. § 1927, Bankruptcy Rule 9011, and Bankruptcy Section 105(a), and the court’s inherent authority in concluding that while sanctions were not appropriate for the law firm, “the Court will impose a certification requirement on the Firm” to ensure that it takes further necessary steps to “prevent future abuse” of GenAI. The court did, however, find that sanctions were appropriate against the specific offending attorney, and publicly reprimanded her, ordered her to inform her clients, opposing counsel, and every court in which she is counsel of this opinion within 31 days, revoked the attorney’s pro hac vice status, and ordered the attorney must provide the clerk of court with a listing of jurisdictions in which she is licensed to practice law within 24 hours of the court’s order.
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Attorneys/Law Firms
S.D. Ala. – Judge Terry F. Moorer	10/10/2025	Generative AI	Generative AI Usage	In United States v. McGee, 2025 U.S. Dist. LEXIS 201350 (S.D. Ala. Oct. 10, 2025), CJA-appointed counsel for the defendant submitted a motion to continue the trial with citations to various non-existent cases and misattributed quotations. During the hearing on the court’s order to show cause as to why the attorney should not be sanctioned, the attorney admitted to using a service called “Ghostwriter Legal” to conduct legal research for the motion, as he believed it was a “reliable research program.” He acknowledged that the research was erroneous and never intended to mislead the court, as he was aware that other GenAI tools, like ChatGPT, could produce hallucinations. The court strongly admonished the attorney, noting that his actions “harm the Defendant, the public, the United States, and indeed the Court,” particularly because this is “a criminal case in which the defendant had an appointed counsel which is paid for pursuant to the CJA which are public funds.” At the end of the hearing, when asked whether he wished to proceed with current counsel, the defendant stated that he “no longer had confidence in his counsel” and requested new representation, even though it would cause considerable delay. The court ultimately (i) imposed a $5,000 fine on the defendant’s attorney; (ii) referred the attorney to the Southern District of Alabama’s panel for consideration as to whether he should be removed from the CJA; (iii) required the attorney to file a copy of this order in any active case where he has appeared on the record, in any case in which he will appear for the next 12 months, and any jurisdiction where he is licensed to practice; and (iv) required the Clerk of Court to send a copy of this order to the Chief Judges for the Northern District and Middle District of Alabama and for submission in the Federal Supplement for deterrence measures.
			Applies to AI Used for Research
			Court-Imposed Consequences – Attorneys/Law Firms
N.D. Ala. -- Judge Anna M. Manasco	7/23/2024	Generative AI	Generative AI Usage	In Johnson v. Dunn, 2025 U.S. Dist. LEXIS 141805, (N.D. Ala. July 23, 2025), after the plaintiff accused the defendant of fabricating five citations to legal authorities in two motions, the court issued a show cause order to the defendant’s attorneys and law firm. In response to the show cause order, three of the defendant’s attorneys confirmed in writing and at a hearing that the citations “were hallucinated by ChatGPT.” Although the court held that Rule 11 does not apply to discovery motions and expressed uncertainty as to whether the local rules or the Alabama rules of professional conduct also applied, the court invoked its inherent authority to issue sanctions against the three defense attorneys. The court declined to sanction two defense attorneys who it concluded were not involved in the drafting of the briefs. Likewise, as a result of the law firm’s internal efforts to prevent GenAI misconduct ( through emails by the firm’s general counsel, the creation of an AI committee, firmwide AI policy, and articles discussing the dangers of AI in legal work), the Court found “no evidentiary basis for a finding that the firm acted in bad faith or with such recklessness that its conduct was tantamount to bad faith” and released the firm from the evidentiary proceedings. For the three sanctioned attorneys, the court publicly reprimanded them for their misconduct, ordered the attorneys to provide a copy of its order to their clients, opposing counsel, and presiding judge in every pending state or federal case in which they are counsel of record as well as every attorney in their law firm, submission of the order for publication in the Federal Supplement, disqualified them for further participation in the case, ordered the attorneys to provide a listing of jurisdictions in which they are licensed to practice law, and sent the order to the general counsel of the Alabama state bar and any other applicable licensing authorities for further proceedings as appropriate.
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Attorneys/Law Firms
N.D Alabama – Judge Haikala	7/8/2024	Generative AI	Generative AI Usage	The order refers to “generative artificial intelligence,” specifically mentioning ChatGPT, Google Bard, and Bing AI Chat, and cautions lawyers that gen AI tools “may produce factually or legally inaccurate content.” The order reminds counsel that attorneys remain responsible for reviewing and verifying “computer-generated content” to ensure it complies with the Federal Rules. There are no prohibitions, disclosure requirements, or other limitations on the use of gen AI tools.
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting

Contacts