No Artificial Intelligence (AI) was used in the drafting of this blog post. The citations to cases herein were all derived from a trial order source. Believe it or not, some courts require such disclosures.
I have been somewhat hard on the uninformed or intellectually challenged who blithely engage AI as if it were a sentient, thinking being. See Prosecuted for lying? (June 2025); Better look that up (July 2025); Avatars to Replace Lawyers? (April 2025). I have said it before, and I repeat it here: lawyers need to be wary of AI (so do judges). Just Delete It? (October 2025).
It is frankly incomprehensible that any lawyer is practicing today who does not know that AI hallucinates and cannot be trusted. Which AI? All of them. "Internal" and "external" are colloquialisms attached to AI, but they are all troublesome. Three intrepid Mississippi explorers are now enjoying their "Warhol 15 minutes" as a result.
The U.S. District Court in Aberdeen, Mississippi (north of Starkville, and south of Tupelo), has addressed the missteps of three lawyers who were part of a firm until recently. The case is styled Billups v. Louisville Municipal School District, Case No. 1:24-CV-74-SA-RP. Just before Christmas, Judge Aycock entered a December 19, 2025, order regarding AI, legal research, and sanctions.
The story is intriguing and involves two law partners, Louis Watson and Nick Norris, and an associate named Jane Watson. It is likely that the two Watsons are father and daughter, but that is not stated in the order. Mr. Norris left the firm in November 2025, informing the Billups court by letter, and the Watsons may still be practicing together.
In September 2025, the District Court investigated the citation of fictitious and hallucinated authorities (cases). These fell into two categories: a non-existent case and "multiple instances where case holdings were misrepresented." These were "immediately identified" by the trial judge, were listed by the judge, and an order to show cause was entered, compelling an explanation. The progress of the case was delayed by the show cause, hearing, and conclusions.
The court concluded that the hallucinations were submitted because of "unverified artificial intelligence ('AI') usage." The judge noted that a similar order in another case, regarding hallucinations, had been entered regarding Ms. Watson's use of "an AI tool to assist her in drafting the brief" and memorialized her admission "that she did not verify the accuracy of the citations generated by the AI tool before submitting the brief to the court."
Before these two instances, in March 2025, Ms. Watson was contacted by an opposing counsel in yet another case regarding "discrepancies." Those were blamed on "unverified AI output," and led to all "three (Watson and Norris) attorneys attend(ing) a continuing legal education ('CLE') course on ethics in utilizing AI."
Education is a great response to errors and mistakes. When you flounder, and we all do periodically, leverage articles, research, and classes to move forward. But, and this is important, taking classes is only worthwhile if you listen, digest, and actually learn. Attendance alone will gain you nothing.
In response to that first instance of AI misuse, the Watson and Norris firm also adopted an AI policy and constraints on its use. Specifically, no "external AI tool" use was permitted, and only the firm's case management AI and related tools, called "Smokeball" and "Archie," were permitted. Does anyone else wonder where the names for these AI LLMs and tools come from?
In the Billups case, the pleading had been signed by the associate attorney, Ms. Watson, under the supervision of the partner, Mr. Norris. Ms. Watson graduated law school in 2022, was hired by the firm in 2023 as a "legal assistant," and was later admitted to the Mississippi Bar in September 2024. There is no patent explanation for the perhaps two-year delay between graduation and bar admission. But see Smarter than Kim (December 2025).
The Billups judge concluded that Ms. Watson "consistently violated the (firm) AI policy since its inception." Following the show cause order, the "firm began reviewing filings" in various cases and found "ten cases wherein briefs" included "unverified and/or inaccurate citations."
Notably, there was at least one misstatement by the firm about these other cases, which the trial judge noted from personal knowledge ("the undersigned is aware of at least five other cases in this District"). When responding to a show cause order or an inquiry from a judge, being precise and accurate is worthwhile. When you don't know, simply say so. If you are guessing, say so. But when you make a factual statement, expect to back it up.
Following the show-cause hearing, Mr. Norris informed the Court via letter that the Watson and Norris firm dissolved effective November 30, 2025, and that Mr. Billups elected for Norris to continue to represent him in this case.
The Billups judge noted Rule 11, reasonable inquiry, certification of contentions, and avoidance of frivolous argument. She noted that there is "a duty to conduct a ‘reasonable inquiry into the facts and law of a case at the time [at] which (an attorney) affixes her signature on any papers to the court.’” The judge reiterated:
"AI is a powerful tool, that when used prudently, provides immense benefits. When used carelessly, it produces frustratingly realistic legal fiction that takes inordinately longer to respond to than create. While one party can create a fake legal brief at the click of a button, the opposing party and court must parse through the case names, citations, and points of law to determine which parts, if any, are true." Ferris v.Amazon.com Servs., 778 F. Supp. 3d 879, 881 (N.D. Miss. Apr. 16, 2025).
The trial judge found fault in
Ms. Watson's:
- Filing of the subject pleading drafted and researched with Grok AI.
- Not verifying the accuracy of the output.
- Not reading the cited cases, in violation of Rule 11.
- Failure "to 'discharge [her] most basic responsibility as an attorney.'"
- "Troublesome pattern of conduct."
- Failure "to change her ways," or "learn() from her mistake."
- "Blatant disregard for the Firm's policy."
Mr. Norris'
- Assuming the cited cases were correct.
- Not reading the cases cited in the brief.
- Not acknowledging that the "attorney's responsibility to review a legal filing for factual and legal accuracy is 'nondelegable.'”
- Not learning from Ms. Watson's first AI usage, which led to the firm's AI policy and more.
- "Indifference to his professional responsibility."
Mr. Watson's
- Failure "as a supervisory attorney."
- Role as "jointly responsible for a violation" of rules.
- The, as yet, absence of any "steps ... taken to sanction or punish or address the wrongdoing of Ms. Watson."
In fairness, being a parent is one of the most difficult tasks on the planet. Punishing your child is excruciatingly difficult. That said, would you rather be their parent or friend? Of course, this assumes they are father and daughter, which is perhaps not the case.
Ms. Watson argued at the show-cause hearing that she was merely "lazy" and had "made a big mistake" in not checking her work. Though she and the firm had "almost six weeks to prepare" for the show cause hearing, "Mr. Watson was learning of new cases involving unverified AI usage by the Firm on the morning of the hearing." That may have been perceived as not very diligent on anyone's part.
The court was not finished, though. The trial judge addressed the defendant in the Billups case. She noted that it "could have flagged the fictitious citation and misrepresentation of case law in a reply brief or supplemental filing." The defendant was not sanctioned, but she clarified in a clarion call:
"Going forward, the Court expects all parties to assist in maintaining the integrity of the judicial process and to be diligent in flagging AI misuse. '[O]therwise, the risk is too great that such errors will persist undetected, potentially leading to an outcome unsupported by law.'” Elizondo v. City of Laredo, 2025 WL 2071072, at 3 (S.D. Tex. July 23, 2025).
The judge noted the three Watson and Norris lawyers had "already attended CLE trainings on the dangers of AI, self-reported to the Mississippi Bar, and informed Billups of the AI misuse." She concluded "that a monetary fine would not have a meaningful deterrent effect" in this instance. Therefore, all three were disqualified from the Billups case.
All three were "required to provide a copy of (the) Sanctions Order to all presiding judges in every pending state or federal case in which they are counsel of record." That embarrassment may be of import. And Ms. Watson was ordered to "seek withdrawal in any case where she appears as attorney of record that is assigned to" that trial judge. She was essentially barred from appearing before that judge for "two (2) years."
Intriguingly, many lawyers include "recent cases" or outcomes on their firm website or social media feeds. One might wonder how effective it could be to order lawyers in similar instances of AI misfeasance to post notice of their "recent discipline," or links to orders such as the one in Billups, on their public-facing web and media platforms?
It is noteworthy that the judge in Billups cited Ferris. The notation there reminds us that it requires significant time and effort to "parse through the case names, citations, and points of law to determine which parts, if any, are true." The Billups judge ordered the three lawyers to:
"conduct an internal audit of all substantive filings on which Jane Watson is a signatory since she became an associate attorney with the Firm. The Firm must provide a report of the audit to this Court identifying: (1) every case in which Jane Watson is a signatory on any filing, (2) any fictious case citations and/or misrepresentations of case holdings in any filing, and (3) the corrective action that has been taken in each case."
That will take some time investment from each. They are fortunate that she was an associate attorney for only about one year. Firms might take note of the potential for similar punishment regarding a lawyer with more years of experience. As the "age of AI" progresses, the "tail" on such potential research will become longer and longer. The time and expense of such research will perhaps become increasingly significant. Learn from the mistakes of others!
Each of the three lawyers was ordered to independently "certify under oath that they reviewed all Ms. Watson's filings and identified all fictitious case citations and/or misrepresentations to the best of their ability." Thus, the parsing and onus of this difficult auditing task fall to the entirety of the law firm and independently on each of the three lawyers, despite the law firm's dissolution.
It is very likely that news of this order will travel rapidly in the realm of Mississippi and beyond. The opposing counsel of any of the three will likely be performing due diligence as the judge's clarion "charge" compels, whether those cases are before her or not. Perhaps a few lawyers elsewhere will take heed and pay more attention to their citations of authority and those of their opponents. It is in hopes of such a positive outcome that I publish this and my prior AI accounts.
Being a lawyer is a privilege. Providing counsel and representation is a tremendous responsibility. The lawyer often holds their client's very life in their hands. The lawyer must be industrious, intellectual, and engaged. They will make mistakes, despite their best efforts. Nonetheless, their best efforts are expected.
In a now-famous scene from Animal House (Universal 1978), Dean Wormer cautioned, "Lazy and stupid is no way to go through life, son." It was worthy then, and it is worthy now. There are no shortcuts that relieve lawyers or judges from professional responsibility. That clarion "charge" should remain daily in each of our foci.