The Brief "Contained False Testimony from Wholly Fabricated Witnesses"

Read the original at Reason ↗
Cite

Volokh, E. (2026, September 14). The Brief "Contained False Testimony from Wholly Fabricated Witnesses". Reason. https://reason.com/volokh/2026/09/14/the-brief-contained-false-testimony-from-wholly-fabricated-witnesses/

Dated when The Aporia collected the article, usually within hours of publication. Check the original for its exact date and byline.

Reason · collected 2026-09-14 · by Eugene Volokh

Quick Summary

New Mexico Supreme Court found attorney Stephen D. Aarons in direct contempt of court for using AI tool ChatGPT to prepare a legal brief containing false testimony from fabricated witnesses and misrepresented legal authority. The court also barred Aarons from appearing before it pending disciplinary board investigation, after he admitted to not verifying the factual claims or informing his client about the issues.
Written by AI on 2026-09-14, from this article's own text only (the story summary below draws on all the coverage).

AI analysis

Story summary

In August 2026, the New Mexico Supreme Court found attorney Stephen D. Aarons in direct contempt of court for using AI tool ChatGPT to prepare a brief that contained false testimony from fabricated witnesses and misrepresented legal authority. The court issued an order on August 21, 2026, stating that Aarons did not verify the factual claims or inform his client about the inaccuracies. He was barred from appearing before the Supreme Court pending disciplinary board proceedings and ordered to pay $5,000 to the State Bar of New Mexico Client Protection Fund as a sanction for contempt. The court also struck down all previous briefing in the case and appointed new defense counsel for the defendant-appellant, ensuring the case would proceed with accurate documentation during the Supreme Court's 2026-2027 term.

Written for “False Testimony Controversy” on 2026-11-02, grounded in this article and the 0 other(s) covering the same event.

Story

📰 False Testimony Controversy
Crime & Law · 1 article(s) covering the same event.

Compared with similar articles

Nothing to compare against. No article is close enough to this one for the pipeline to have linked or judged the pair.
How this article was measured signals, leaning charts, publisher record, byline, topics and claims

Signals How these are calculated →

Claims extracted
2
sentences that state something as happening or true
Uncertain
50%
1 of 2 hedged ("reportedly", "may", "according to")
Leaning
not political
takes no side on a contested political question
Publisher signals
67/100
Reason's corrections and hedging, across everything collected from it. Not a measure of accuracy.
Outlets on this story
1
Crime & Law
Same framing elsewhere
1
articles that frame the event the way this one does
Analyzed 2026-09-14 · how these are computed

How this is being covered How these are calculated →

Article leaning vs. publisher reliability
Source leaning vs. consistency

Publisher

Reason · 1053 article(s) · 4 correction(s) detected
Running correction rate · 4 correction(s)

Who wrote this

Eugene Volokh
183 article(s) here · 1 carrying a prediction
🔮 Some excerpts from the long First Superseding Indictment in U.S. v. Hakim (E.D. Mich.), filed Oct. 21, alleging conspiracy to transmit threats in interstate commerce as well as, for two defendants, witness intimidation and destruction of property to prevent seizure (8 of the 12 defendants had originally been indicted in May); the targets included UM officials and businesses connected with them, as well as the Jewish Federation of Metropolitan Detroit:
🔮 Because "[t]he costs and efforts required to defend a lawsuit through [discovery] could chill free speech nearly as effectively as the absence of the actual malice standard altogether[,]" a public figure plaintiff must plausibly allege actual malice at the outset of the litigation.
🔮 The First Amendment forbids a State from using its investigative power that way, and I will not allow it while this case is pending.
🔮 The same logic could apply to nuns who had felt religious pressure to do the educational or nursing work that their order was known for, or to monks who had felt religious pressure to do agricultural work that supports the monastery.
2026-10-30 · assertive framing · Amicus Brief in OneTaste Criminal Prosecution
🔮 Before doing so, "he entered the coffee shop to purchase a cookie, which he hoped would be seen as a sign of goodwill."
🔮 While individuals who are the subjects of unwanted speech may be able to limit some speech directed to them, they cannot limit offensive speech about them directed to others.
🔮 Because "the conduct regulated depend[ed] on—and [could not] be separated from—the ideas communicated," Florida's law was "functionally a regulation of speech" implicating the First Amendment.
🔮 You might assume that some judge is "woke" or "Trumpy" or what have you, but there's a pretty good chance that the judge's legal analysis is still correct.
🔮 The hope would be to siphon votes away from Sullivan.
🔮 Alas, like other formerly unique human skills, I expect this one too will fall victim to competition from AI.
Also by Eugene Volokh
Open Thread
2026-11-01 · Reason
Nothing else under this byline is closely related to this article, so these are simply their most recent.
All 183 articles by Eugene Volokh →

Topics

Ars Technica ChatGPT Court the Disciplinary Board the New Mexico Supreme Court

Subjects

Court ORG · 4× Stephen D. Aarons PERSON · 3× the Disciplinary Board ORG · 3× Ars Technica ORG · 2× Teresa Marquez PERSON · 2× Jon Brodkin PERSON · 1× Michelle Amarillo PERSON · 1× Sanchez PERSON · 1× Sandoval PERSON · 1× the New Mexico Supreme Court ORG · 1×

Narrative

Mostly law professors | Sometimes contrarian | Often libertarian | Always independent From the New Mexico Supreme Court last week in State v. Sandoval, via Ars Technica (Jon Brodkin): WHEREAS, Respondent acknowledged to the Court in his written response and oral argument that he used the generative artificial intelligence (AI) tool ChatGPT in the preparation of the brief in chief he filed with the Court; WHEREAS, Respondent admitted to the Court that the brief in chief contained false testimony from wholly fabricated witnesses—Officer Michelle Amarillo, Officer Sanchez, Manal Al-Jibury, and Teresa Marquez; false testimony from Danny Stanton that he received threats, which he took seriously, from Defendant-Appellant; false testimony from Linda Stanton about the threats her husband received; false testimony from Mariah Chavez and Teresa Marquez (fabricated witness) regarding the shooter's clothing and appearance; and misrepresented legal authority in State v. Lopez, 2005-NMSC-018, 138 N.M. 9, 116 P.3d 80 and State v. Manus, 1979-NMSC-035, 93 N.M. 95, 597 P. 2d 280;
framing: mixed · carried by 1 article(s) · first seen 2026-09-14
🔮 WHEREAS, 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; {WHEREAS, this matter came on for consideration by the Court upon its own motion to show cause, whereupon the Court issued an order to show cause to Respondent, Defendant-Appellant's attorney Stephen D. Aarons, directing him to show cause in person before the Court on August 21, 2026, why he should not be held in contempt and referred to the Disciplinary Board for the factual and legal misrepresentations he made to the Court in his brief in chief, and response thereto;} WHEREAS, Respondent also admitted to the Court that he did not inform his client of the order to show cause proceedings or provide his client with copies of the order to show cause pleadings; WHEREAS, the Court having considered the response and oral argument presented, concludes that Respondent demonstrated a lack of remorse and a lack of concern for his client; … Chief Justice Julie J. Vargas, Justice Michael E. Vigil, Justice C. Shannon Bacon, Justice David K. Thomson, and Justice Briana H. Zamora concurring; NOW, THEREFORE, IT IS ORDERED that Respondent, STEPHEN D. AARONS, is found in DIRECT CONTEMPT OF COURT; IT IS FURTHER ORDERED that this matter, with respect to Respondent, is hereby referred to the Disciplinary Board for further consideration; IT IS FURTHER ORDERED that Respondent is barred from appearing before this Court, pending the outcome of the investigation and proceedings, if any, before the Disciplinary Board; IT IS FURTHER ORDERED that, following the Disciplinary Board investigation and proceedings, if any, the Court will make further determinations regarding Respondent in accordance with the Rules Governing Discipline; IT IS FURTHER ORDERED that the Law Office of the Public Defender is hereby appointed to represent Defendant-Appellant in this appeal and shall assign counsel to this matter who shall enter an appearance on behalf of Defendant-Appellant forthwith; IT IS FURTHER ORDERED that all briefing filed in this matter is hereby STRICKEN; IT IS FURTHER ORDERED that, following the entry of appearance of new defense counsel, a new briefing order shall be issued and the case will proceed with the intention that it will be heard during the Court's 2026-2027 term; IT IS FURTHER ORDERED that as a sanction for direct contempt, Stephen D. Aarons shall, within thirty (30) days of the date of this order, pay a sum of five thousand dollars ($5,000) to the State Bar of New Mexico Client Protection Fund and shall notify the Court in writing when such payment is made …. Read the Ars Technica story for more.

Claims (2 extracted, 1 hedged)

Mostly law professors | Sometimes contrarian | Often libertarian | Always independent From the New Mexico Supreme Court last week in State v. Sandoval, via Ars Technica (Jon Brodkin): WHEREAS, Respondent acknowledged to the Court in his written response and oral argument that he used the generative artificial intelligence (AI) tool ChatGPT in the preparation of the brief in chief he filed with the Court; WHEREAS, Respondent admitted to the Court that the brief in chief contained false testimony from wholly fabricated witnesses—Officer Michelle Amarillo, Officer Sanchez, Manal Al-Jibury, and Teresa Marquez; false testimony from Danny Stanton that he received threats, which he took seriously, from Defendant-Appellant; false testimony from Linda Stanton about the threats her husband received; false testimony from Mariah Chavez and Teresa Marquez (fabricated witness) regarding the shooter's clothing and appearance; and misrepresented legal authority in State v. Lopez, 2005-NMSC-018, 138 N.M. 9, 116 P.3d 80 and State v. Manus, 1979-NMSC-035, 93 N.M. 95, 597 P. 2d 280; asserted
husband → acknowledge → Manus
WHEREAS, 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; {WHEREAS, this matter came on for consideration by the Court upon its own motion to show cause, whereupon the Court issued an order to show cause to Respondent, Defendant-Appellant's attorney Stephen D. Aarons, directing him to show cause in person before the Court on August 21, 2026, why he should not be held in contempt and referred to the Disciplinary Board for the factual and legal misrepresentations he made to the Court in his brief in chief, and response thereto;} WHEREAS, Respondent also admitted to the Court that he did not inform his client of the order to show cause proceedings or provide his client with copies of the order to show cause pleadings; WHEREAS, the Court having considered the response and oral argument presented, concludes that Respondent demonstrated a lack of remorse and a lack of concern for his client; … Chief Justice Julie J. Vargas, Justice Michael E. Vigil, Justice C. Shannon Bacon, Justice David K. Thomson, and Justice Briana H. Zamora concurring; NOW, THEREFORE, IT IS ORDERED that Respondent, STEPHEN D. AARONS, is found in DIRECT CONTEMPT OF COURT; IT IS FURTHER ORDERED that this matter, with respect to Respondent, is hereby referred to the Disciplinary Board for further consideration; IT IS FURTHER ORDERED that Respondent is barred from appearing before this Court, pending the outcome of the investigation and proceedings, if any, before the Disciplinary Board; IT IS FURTHER ORDERED that, following the Disciplinary Board investigation and proceedings, if any, the Court will make further determinations regarding Respondent in accordance with the Rules Governing Discipline; IT IS FURTHER ORDERED that the Law Office of the Public Defender is hereby appointed to represent Defendant-Appellant in this appeal and shall assign counsel to this matter who shall enter an appearance on behalf of Defendant-Appellant forthwith; IT IS FURTHER ORDERED that all briefing filed in this matter is hereby STRICKEN; IT IS FURTHER ORDERED that, following the entry of appearance of new defense counsel, a new briefing order shall be issued and the case will proceed with the intention that it will be heard during the Court's 2026-2027 term; IT IS FURTHER ORDERED that as a sanction for direct contempt, Stephen D. Aarons shall, within thirty (30) days of the date of this order, pay a sum of five thousand dollars ($5,000) to the State Bar of New Mexico Client Protection Fund and shall notify the Court in writing when such payment is made …. Read the Ars Technica story for more. uncertain
payment → admit → more
💬Give feedback
🕘History 🎫Support