Holding / Framework
Disciplinary court approved stipulated suspension establishing the state-bar disciplinary framework for AI-driven citation hallucinations: filing AI-generated authorities without verification implicates competence and diligence rules; subsequent dishonesty about the source of the errors implicates candor and misrepresentation rules. The compounding-misconduct pattern (AI hallucination plus deception about origin) is what drove the actual-suspension component beyond what citation-only conduct typically merits.
Triggering Conduct
Attorney drafted and filed a motion to set aside judgment in a civil case using case law obtained from ChatGPT, without reading the cases or verifying the citations were accurate. Before the hearing, attorney discovered the cited cases were either incorrect or fictitious. After the court flagged the citations, attorney made false statements to the judge attributing the errors to a legal intern, who in fact had no involvement.
Sanctions / Disposition
Suspension of one year and one day, with 90 days actively served and the remainder stayed upon successful completion of a two-year probation period. Violations: Colorado Rules of Professional Conduct 1.1 (competence), 1.3 (diligence), 3.3(a)(1) (candor toward tribunals), 8.4(c) (dishonesty / misrepresentation).
Primary Source
https://www.coloradolegalregulation.com/wp-content/uploads/PDJ/Decisions/Crabill,%20Stipulation%20to%20Discipline,%2023PDJ067,%2011-22-23.pdf · court_website
Tags
state_bar_discipline, hallucinated_citations, suspension, attorney, candor_violation, framework_setter, compounding_misconduct