People v. Crabill
Bar disciplineColorado Office of the Presiding Disciplinary Judge · Colo. OPDJ · Decided November 22, 2023
- Citation:
- People v. Crabill, No. 23PDJ067 (Colo. OPDJ Nov. 22, 2023)
- AI tool:
- ChatGPT
- Sanction amount:
- 1 year + 1 day suspension; 90 days active
What happened
Attorney Zachariah Crabill used ChatGPT to generate case citations and submitted them in a motion without verification. He discovered the citations were fictitious before a hearing but did not alert the court or withdraw the motion. When confronted by the court, he falsely attributed the errors to a legal intern. Six days later, he filed an affidavit disclosing his ChatGPT use.
Outcome
Total suspension 1 year and 1 day; 90 days active suspension; remainder stayed on 2-year probation with conditions. Presiding Disciplinary Judge approved stipulation to discipline. Violations: Colo. RPCs 1.1 (competence) and 1.3 (diligence) for failing to verify; 3.3(a)(1) (candor to the tribunal) for failing to alert the court or withdraw the motion after discovering the fabrications; and 8.4(c) (dishonesty/misrepresentation) for falsely attributing the errors to an intern. The coverup was the aggravating factor that elevated the sanction from a reprimand to active suspension.
People v. Crabill was the first active bar suspension in the United States for conduct arising from AI-hallucinated citations. The facts matter because they establish the operative lesson: the coverup was worse than the error. Filing fabricated citations violated Rules 1.1 and 1.3; the 90-day active suspension turned on the Rule 3.3 failure to correct and the Rule 8.4(c) misdirection to an intern. For attorneys evaluating an AI hallucination that has already reached a filing, Crabill is the cautionary case — prompt correction is the only defensible path.
Primary sources
Last verified: April 24, 2026. Verify against primary sources before relying on this in a filing.