The Georgia Supreme Court on May 5, 2026 disciplined Deborah Leslie, an assistant district attorney in Clayton County, finding that her misuse of artificial intelligence tools introduced fake and misleading case citations into a murder case ruling. The court barred Leslie from appearing before the justices for six months and ordered her to complete additional legal education on ethics, brief writing, and proper AI use.
The case arose from the appeal of Hannah Payne, who was sentenced to life in prison plus 13 years for the murder and false imprisonment of Kenneth Herring. Leslie prepared a proposed order urging the trial judge to deny Payne's request for a new trial. That proposed order contained AI-generated citations, including cases that did not exist. The trial judge adopted much of Leslie's proposed order, including the fabricated citations, when issuing the formal ruling.
The Georgia Supreme Court found that "numerous fictitious or misattributed case citations" appeared in the lower court's 2025 order. Justice Benjamin Land wrote that citing cases that do not exist violates court rules and "falls far beneath the conduct we expect from Georgia lawyers." The court vacated the ruling and ordered the trial judge to issue a new order without fictitious citations.
Leslie apologized in an earlier court filing for failing to independently verify the AI-generated citations. The Clayton County District Attorney's Office did not respond publicly to the disciplinary action.
The case is among the rarer instances of a prosecutor facing AI-related discipline. Courts have more frequently sanctioned defense attorneys and civil litigants. The Georgia Supreme Court urged trial judges going forward to review proposed orders with the understanding that AI software may have been used, and to apply appropriate scrutiny before adopting any proposed language.
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