Slay v. Ross
Court of Appeals of Georgia · Ga. Ct. App. · Georgia bar guidance
Verified May 14, 2026
- Citation
- Slay v. Ross, Ga. Ct. App. (Mar. 9, 2026)
- Decided
- March 9, 2026
Summary
Georgia Court of Appeals decision in which the panel identified fabricated case citations in a party's appellate filing. Consistent with the court's developing approach following Shahid v. Esaam (Ga. Ct. App. 2025), the panel treated the defective citations as the product of generative AI use without independent verification. The court declined to impose a monetary sanction and instead issued a warning to counsel about the duty to verify every citation against the primary source before filing.
- AI tool:
- Implied (specific generative AI product not identified on the face of the opinion)
- Sanction amount:
- None
What sanction did the court impose?
Warning to counsel; no monetary sanction. The court's discussion reinforces that even a first-offense fabricated-citation incident before a Georgia appellate panel will draw an explicit on-the-record admonition.
Why does Slay v. Ross matter for law firms using AI?
Slay v. Ross is a Georgia Court of Appeals decision in the line that began with Shahid v. Esaam: a Georgia appellate panel called out fabricated citations in a party’s brief and treated the failure to verify as the lawyer’s, not the tool’s. The outcome here, a warning rather than a fine, is the floor, not the ceiling. For a managing partner in Atlanta, Savannah, or Macon, the practical signal is that Georgia appellate panels are now actively reading for hallucinated citations and will memorialize a warning in a published or unpublished opinion even on a first offense. The compliance ask is unchanged from prior cases: every cite in every filing must be opened and read against the primary source, and the firm should be able to document who did that verification and when.
Sources
Primary sources
Further reading
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
- https://www.damiencharlotin.com/hallucinations/
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.