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HomeCasesSlay v. Ross
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Corpus matter record

Slay v. Ross

CA Georgia · Mar 9, 2026

GA / stateEditorial impact: lowfake citationsfamilyappellateWarning
Direct answer

What happened in this matter?

The Georgia Court of Appeals issued a warning to counsel after identifying four fabricated case citations in an appellate brief. The court explicitly linked these hallucinations to the irresponsible use of generative AI and noted the counsel's history of similar conduct in other litigation.

Why the court cared
The court reasoned that the inclusion of fictitious cases is a hallmark of irresponsible AI use. It determined that while the fictitious citations did not impede the opposing party's ability to respond in this specific instance, the conduct was nonetheless improper and part of a broader pattern of deficient filings by the same counsel.
Why it matters now
Four fabricated citations in one brief is a pattern, not a typo; require a verification log before any appellate filing leaves the firm.

Why this matter is tracked

In an appeal regarding child custody and support, the Georgia Court of Appeals identified that the appellant's brief contained multiple fictitious case citations, including Waller v. Waller, Johnson v. Johnson, Durden v. Barron, and In re Waitz. The court attributed these hallucinations to the irresponsible use of generative artificial intelligence in legal drafting. While the court affirmed the trial court's underlying rulings on custody and attorney fees, it issued a formal warning regarding the counsel's conduct. The court noted that the appellant's counsel had previously submitted briefs with similar defects in federal district court, indicating a pattern of behavior rather than an isolated error.

Operational lesson

Four fabricated citations in one brief is a pattern, not a typo; require a verification log before any appellate filing leaves the firm.

Record details

GeorgiaSingle-state evidence scope
Explore GAOpen its source-linked jurisdiction page and related matters.
CourtCA Georgia
Jurisdictionstate
Circuit11th Circuit
DateMar 9, 2026
GE
AI toolGenerative Artificial Intelligence (unspecified)
Party typeLawyer
OutcomeThe court affirmed the trial court's judgment and issued a formal warning to counsel regarding the submission of hallucinated citations.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

implied

The court attributed the hallucinations to the use of generative artificial intelligence.

Procedural posture

Appellate review of trial court orders regarding child custody, visitation, and contempt.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

4 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Appellant's brief cited Waller v. Waller, 288 Ga. 164, 164-165 (2010), which the court found to be fictitious; court noted as an example of AI-generated bogus citation.
  2. Fabricated: Case Law | Appellant's brief cited Johnson v. Johnson, 286 Ga. 720, 721 (2010), which the court found to be fictitious; cited as part of the pattern of hallucinated cases.
  3. Fabricated: Case Law | Appellant's brief cited Durden v. Barron, 287 Ga. 858 (2010), which the court determined does not actually exist and flagged as a bogus citation.
  4. Fabricated: Case Law | Appellant's brief cited In re Waitz, 255 Ga. 474 (1986), which the court identified as another nonexistent authority in the brief.

Questions this record answers

What happened in Slay v. Ross?
The Georgia Court of Appeals issued a warning to counsel after identifying four fabricated case citations in an appellate brief. The court explicitly linked these hallucinations to the irresponsible use of generative AI and noted the counsel's history of similar conduct in other litigation.
Why does Slay v. Ross matter for legal AI risk?
Four fabricated citations in one brief is a pattern, not a typo; require a verification log before any appellate filing leaves the firm.
What does the public record establish about Slay v. Ross?
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Which source supports this Slay v. Ross summary?
The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.

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