ATLANTA (LN) — The Georgia Supreme Court on Tuesday suspended Clayton County Assistant District Attorney Deborah Leslie’s privilege to practice for six months after she acknowledged using artificial intelligence software to draft briefs and a proposed order containing non-existent case citations.
Justice Land wrote for the unanimous court that Leslie’s filings in Payne v. State included nine case citations that either did not exist or did not support the legal propositions asserted. The court noted that Leslie failed to independently verify the accuracy of the citations generated before including them in the State’s briefs opposing a motion for new trial and in a proposed order denying the motion.
Hannah Payne was sentenced to life in prison plus 13 years for the murder and false imprisonment of Kenneth Herring and possession of a firearm during the commission of a felony.
The Supreme Court said the misconduct sidetracked the court from resolving the merits of Payne’s appeal and forced it to devote significant time and resources to discovering the errors.
Land wrote that citing cases that do not exist or do not support the proposition for which they are cited is a violation of the court’s rules and falls far beneath the conduct expected from Georgia lawyers.
Leslie acknowledged in a supplemental brief and affidavit that she used artificial intelligence software to draft the State’s briefs and the trial court’s proposed order. She identified 12 additional cases in her trial court briefing that were generated, not independently verified, and did not stand for the propositions for which they were offered.
The court admonished both Leslie and the Clayton County District Attorney’s Office. As a condition of reinstatement, Leslie must complete 12 hours of continuing legal education on ethics, brief writing, and the proper use of artificial intelligence software system.
The Supreme Court vacated the trial court’s September 2025 order denying Payne’s motion for new trial and remanded the case with instructions to issue a new order that does not contain fictitious or misattributed citations. The court directed that the new order not be prepared by counsel for either party.
Justices LaGrua and Colvin concurred in part and dissented in part, objecting only to the admonishment of the elected District Attorney. They noted that the District Attorney had apologized and implemented new policies to address the use of artificial intelligence.