Hicks v. City of Albany
Court of Appeals of Georgia · Ga. Ct. App. · Georgia bar guidance
Verified May 14, 2026
- Citation
- Hicks v. City of Albany, No. A25A2140, 2026 WL 537755 (Ga. Ct. App. Feb. 26, 2026) (Rickman, P.J.)
- Decided
- February 26, 2026
Summary
Appellant's counsel Jessica Carol Idlett (with Robert Mason Beauchamp) filed an initial brief in a municipal ante litem notice appeal that cited two nonexistent cases, Knight v. Pierson, Inc., 206 Ga. App. 514 (1992), and City of LaGrange v. Bolden, 261 Ga. 77 (1991). The City flagged the inaccurate Knight citation in its response brief, but counsel did not explain the fabricated citations until the Court of Appeals issued an order compelling her to do so. Counsel took responsibility and apologized, stating she believed the citations came from an AI platform. Presiding Judge Rickman, joined by Judges Gobeil and Davis, declined to impose sanctions but published a formal warning to the bar.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction or formal discipline imposed. The panel declined sanctions because counsel accepted responsibility and apologized, but issued a published warning that "this troubling practice has become far too common" and that future failures to ensure citation accuracy may subject counsel to sanctions under Court of Appeals Rule 7. Judgment on the underlying appeal was affirmed on the merits.
Why does Hicks v. City of Albany matter for law firms using AI?
Hicks is the second published Georgia Court of Appeals opinion in roughly a year (after Shahid v. Esaam) to address counsel filing AI-fabricated citations, and the panel signals diminishing patience: an apology spared this lawyer, but the court explicitly cautions the bar that the next instance is likely to draw Rule 7 sanctions. For a managing partner, the pattern to note is procedural rather than substantive. Opposing counsel caught the bad citation in its response brief, and the lawyer’s failure to address the problem until the court ordered her to do so is what elevated the matter into a published footnote with her name attached.
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.
- Slip opinion not yet located on the Georgia Court of Appeals website or a free primary mirror; only the Westlaw citation (2026 WL 537755) was available at the time of verification.