Shahid v. Esaam
Court sanctionGeorgia Court of Appeals, First Division · Ga. Ct. App. · Decided June 30, 2025
- Citation:
- Shahid v. Esaam, 2025 Ga. App. LEXIS 299, No. A25A0196 (Ga. Ct. App. June 30, 2025)
- AI tool:
- AI (unspecified)
- Sanction amount:
- $2,500
What happened
Attorney Diana Lynch submitted briefs in a divorce proceeding containing 11 fabricated citations out of 15 total. The trial court had itself relied on two fictitious cases apparently imported from appellee's brief. On appeal, the Court of Appeals vacated the trial court's order and remanded for a new hearing. The court imposed the maximum available sanction under Georgia Court of Appeals Rule 7(e)(2).
Outcome
Trial court order vacated and remanded. $2,500 penalty imposed on attorney Lynch for filing a frivolous motion for attorney fees -- the maximum available under Ga. Ct. App. R. 7(e)(2). The court cited Chief Justice John Roberts' 2023 Year-End Report on AI hallucinations, noting AI applications are 'prone to hallucinations' causing submission of cites to non-existent cases. The court's willingness to impose the maximum available penalty was the operative signal.
Shahid v. Esaam is Georgia’s clearest signal on AI-hallucinated citations: the Court of Appeals went to the top of its available sanction range and did not save the maximum for a more egregious future case. The opinion is also notable for its doctrinal ripple — the trial court had adopted fictitious citations from the appellee’s brief, illustrating how an unverified AI filing can contaminate the decision being appealed.
Primary sources
Last verified: April 24, 2026. Verify against primary sources before relying on this in a filing.