In the Matter of a Member of the State Bar of Arizona, John A. Griffiths

What sanction did the court impose?

On March 13, 2026, Presiding Disciplinary Judge Lisa A. VandenBerg accepted the agreement and entered a final judgment reprimanding Griffiths and ordering him to pay the State Bar's costs and expenses of $1,200.00 within 30 days. Griffiths conditionally admitted violating ERs 1.1 (competence), 1.3 (diligence), 3.1 (meritorious claims and contentions), and 8.4(d) (conduct prejudicial to the administration of justice). The parties agreed his mental state was negligent, that his conduct caused actual harm to the client, the profession and the legal system, and relied on ABA Standards 4.43 and 6.13, with one aggravating factor (substantial experience) and three mitigating factors (no prior record, no dishonest or selfish motive, and cooperation). The PDJ wrote of having "initially struggled with the agreed upon sanction given the failure to take remedial action," noted that "AI legal research is a new and dynamic resource that some lawyers are just now beginning to learn how to use as a tool for their practice," and said it was his "lack of a prior disciplinary record in over 24 years of practice" that led the PDJ to accept the agreement. No formal complaint was filed; probable cause was found on November 18, 2025.

Why does In the Matter of a Member of the State Bar of Arizona, John A. Griffiths matter for law firms using AI?

Griffiths is a consent discipline matter that grew out of a single summary judgment response. The facts come from the conditional admissions the Presiding Disciplinary Judge incorporated by reference: Griffiths used Eve.legal to draft the response, did not cite-check or read the cases it supplied, and filed it. One citation, to a “Doe v. Arizona Hospital Healthcare Ass’n,” did not exist; another, Summers v. Gloor, is a real case that neither supports the proposition nor contains the quoted sentence. Defense counsel pointed out the nonexistent case, and the trial judge raised the citation problem at a hearing and offered Griffiths 15 days to respond in writing. He filed nothing.

The trial judge’s handling shaped what followed. Judge Hannah declined Rule 11 sanctions because the defendants had not requested them, no Rule 11(c)(2) consultation had occurred, and Griffiths had not been asked to withdraw or correct the filing. He referred the matter to the State Bar instead. The discipline that resulted rests on the competence, diligence, meritorious-contentions and administration-of-justice rules, and on the parties’ stipulation that Griffiths acted negligently and caused actual harm to the client, the profession and the legal system. For the sanction, the parties relied on ABA Standard 4.43 (lack of diligence) and Standard 6.13, which addresses negligence in determining whether statements or documents are false or in taking remedial action.

The PDJ’s order is candid about the sanction. The PDJ wrote of having “initially struggled with the agreed upon sanction given the failure to take remedial action,” but accepted a reprimand in light of the agreed negligent mental state, the newness of AI legal research as a tool, and Griffiths’s lack of any prior discipline in more than 24 years of practice. Firms documenting compliance may wish to consider that, in this matter, the disciplinary judge named the failure to take remedial action after notice as the reason for initial hesitation over a reprimand, and that the lawyer has since discontinued his use of Eve.legal, as the agreement records.