The New Mexico Supreme Court held criminal-defense attorney Stephen Aarons in direct contempt on September 9, 2026, after an AI-assisted appellate brief included testimony from four wholly fabricated witnesses, false testimony involving other people and inaccurate descriptions of legal precedents. The court fined him $5,000, referred him to disciplinary proceedings, barred him from appearing before the court while those proceedings are pending, struck the previous briefs and ordered new counsel for his former client, Oscar Renee Sandoval.
The case is a sharp reminder that professional responsibility follows the person who signs a legal filing. The court’s focus was not ChatGPT use in isolation; it was the decision to file factual and legal material without checking it.
What the New Mexico Supreme Court ordered
The remedies affected both Aarons and Sandoval’s appeal. The fine is payable to the State Bar of New Mexico Client Protection Fund, while the appearance restriction applies to Aarons before the New Mexico Supreme Court during the disciplinary proceedings.
| Measure | Outcome |
| Direct contempt | The court held Stephen Aarons in direct contempt. |
| Fine | $5,000 payable to the State Bar of New Mexico Client Protection Fund. |
| Disciplinary referral | The matter was referred for disciplinary proceedings. |
| Appearance restriction | Aarons was barred from appearing before the New Mexico Supreme Court while those proceedings are pending. |
| Existing briefs | The court struck the previous briefs. |
| New representation | The public defender’s office was ordered to appoint new counsel for Oscar Renee Sandoval. |
The order does not establish a final disbarment. It establishes the contempt finding, the interim appearance restriction and the referral to discipline.
What the AI-assisted brief got wrong
The court identified four wholly fabricated witnesses in the filing:
- Officer Michelle Amarillo
- Officer Sanchez
- Manal Al-Jibury
- Teresa Marquez
That was only one category of error. The brief also attributed false testimony to other people, including Danny Stanton, Linda Stanton and Mariah Chavez, and included testimony connected to Teresa Marquez. It inaccurately described real legal precedents as well.
That distinction matters. Fabricated witnesses, false or misidentified testimony involving other people, and incorrect descriptions of legal authority are separate failures—not one interchangeable bucket labeled “fake testimony.”
The workflow Stephen Aarons described
Aarons said he fed a computer-generated transcript from Rev.com, the case record, a statement of issues and discovery materials into ChatGPT. He also said the version he used was powered by OpenAI o3.
The court’s finding concerned what appeared in the filed brief and Aarons’s failure to verify it before submission. A fluent summary is not a reliable legal record by default, and a polished paragraph can still contain a witness who never existed or a precedent described incorrectly. That is the trap in one sentence: readability is not verification.
Why Oscar Renee Sandoval’s appeal became the central consequence
Oscar Renee Sandoval was sentenced to life in prison in February 2025 after a murder conviction. The brief problems did not remain an abstract dispute about artificial intelligence: the court removed the existing appellate briefs and ordered new representation for Sandoval.
| Date or term | Case event | Consequence for the appeal |
| February 2025 | Oscar Renee Sandoval was sentenced to life in prison after his murder conviction. | The sentence led to the appeal handled by Aarons. |
| March 2025 | Aarons agreed to handle the appeal and said he began using ChatGPT to summarize the proceedings. | Case materials entered the AI-assisted workflow he later described. |
| August 2025 | Aarons submitted the appellate brief containing fabricated testimony and other errors. | The filing became the subject of the court’s contempt proceeding. |
| August 21, 2026 | The New Mexico Supreme Court held a show-cause hearing. | Aarons answered questions about the filing and his use of ChatGPT. |
| September 9, 2026 | The court issued its contempt order. | The previous briefs were struck and new counsel was ordered. |
| 2026–27 term | The appeal is scheduled to proceed with new representation. | Sandoval’s appeal continues with a different legal team. |
Why verification—not the brand of tool—decided the case
The justices treated the filing lawyer as responsible for every factual and legal assertion placed before the court. That duty does not change because the text came from ChatGPT, a junior lawyer or another outside source.
This is why the case is broader than a warning about one chatbot. Generative AI can assemble convincing prose from a prompt, but legal filings depend on traceable testimony, accurate case law and precise records. Those elements must be checked against the underlying material before a lawyer signs and files the document.
The court’s response also shows the practical cost of skipping that step: a fine, disciplinary proceedings, an appearance bar and a rebuilt appeal for the client whose case was supposed to be advanced.
What happens next
The New Mexico Supreme Court has referred Aarons to disciplinary proceedings and barred him from appearing before the court while those proceedings are pending. The appeal is set to proceed in the 2026–27 term with new counsel for Oscar Renee Sandoval.
The bottom line is blunt: AI can assist with legal work, but the lawyer who files the document owns its errors—and the client may pay the immediate procedural price.
