A federal judge has ordered prominent Alabama prison defense attorney William Lunsford and several of his colleagues at Butler Snow LLP to appear in court and explain why they should not face sanctions for filing a legal motion that included allegedly fabricated case citations.
U.S. District Judge Anna Manasco issued the order after attorneys representing Frankie Johnson, an incarcerated man who is suing former Alabama Department of Corrections Commissioner Jeff Dunn, alleged that defense lawyers relied on fictitious legal precedents — possibly generated using artificial intelligence — in a court filing earlier this month.
“Defendant [Dunn’s legal counsel] appears to have wholly invented case citations in his Motion for Leave, possibly through the use of generative artificial intelligence,” Jamilah Mensah, Johnson’s lawyer, wrote in a filing last week.
Alleged in the order, lawyers cited sources in the motion that were “not there.”
“In the light of the seriousness of the accusation, the court has conducted independent searches for each allegedly fabricated citation, to no avail,” U.S. District Judge Anna Manasco wrote. “Accordingly, each of the four attorneys who signed Defendant Dunn’s motion for leave, and the Butler Snow law firm, are ORDERED to show good cause, if there be any, why they should not be sanctioned … for making false statements of fact or law to the court.”
Manasco strongly denied any motion to excuse Lunsford.
“The hearing before Judge Treadwell is set for Thursday, May 22, 2025, at 9:00 a.m.. ET – 23 hours after the show cause hearing in this Case,” she stated. “The May 21, 2025 show cause hearing will last no longer than an hour. Accordingly, Mr. Lunsford will have ample time to travel to Georgia in advance of his hearing the next day, and the motion to excuse as to Mr. Lunsford and Mr. Chism is DENIED.”
The judge has paused Johnson’s case until further notice.
Austen Shipley is the News Director for Yellowhammer News. You can follow him on X @ShipleyAusten