Brown v. State of Mississippi
Court of Appeals of Mississippi · Miss. Ct. App. · Mississippi bar guidance
Verified May 14, 2026
- Citation
- Brown v. State, No. 2024-KA-00489-COA, 2026 WL 670733 (Miss. Ct. App. Mar. 10, 2026)
- Decided
- March 10, 2026
Summary
Edwin Terrell Brown's appellate counsel (Merrida Coxwell, Charles Richard Mullins, Courtney Denise Sanders, and Madeline Beard) filed a brief in this capital murder appeal that, on the Rule 404(b) "other crimes" issue, cited three nonexistent cases, misattributed facts, analyses, quotations, and holdings to five otherwise genuine citations, and cited seven additional cases for quotations that do not appear in those opinions. The State flagged the defects in its appellee brief; Brown's reply brief acknowledged the errors, including the "phantom cases." Presiding Judge Carlton, writing for an en banc court, called out the fabrications in footnote 4 of the published opinion before affirming Brown's convictions for capital murder and armed robbery.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction, suspension, or bar referral imposed. The Court of Appeals memorialized the fabricated and misattributed citations in a footnote of its published opinion and affirmed the convictions. The public footnote naming counsel and identifying the "phantom cases" is itself the reputational consequence; the underlying convictions (life without parole for capital murder, ten consecutive years for armed robbery with five suspended) were unaffected.
Why does Brown v. State of Mississippi matter for law firms using AI?
Brown is a quieter but more dangerous variant of the hallucination pattern: a four-attorney appellate team, on a capital murder appeal, filed a brief riddled with phantom cases and fabricated quotations that survived whatever internal review the firm conducted. The court declined to impose monetary sanctions or a referral, but it named the attorneys in a published opinion footnote that will follow them through any future Westlaw search of their names. For a managing partner, the lesson is that the highest-stakes filings (capital appeals, dispositive motions, appellate briefs) are precisely where AI-assisted drafting is most tempting and least supervised, and that a court’s “no formal sanction” disposition still produces a permanent, searchable public record of the lapse.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- No separate show-cause order or disciplinary referral is described in the opinion text obtained; whether the Mississippi Bar opens a follow-on inquiry is not addressed in the affirmance.