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State v Sandoval

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Case Information
Case name State v. Sandoval / In re Stephen D. Aarons[1]
Court New Mexico Supreme Court[1]
Docket S-1-SC-40845[1]
Filed Appeal filing date not established in the reviewed order.
Judge(s) Per curiam; all five justices concurred.[1]
Plaintiffs State of New Mexico (appellee)[1]
Defendants Oscar Renee Sandoval (appellant); Stephen D. Aarons (contempt respondent)[1]
Case type Criminal appeal; attorney contempt[1]
Claims / issues Unverified AI-assisted briefing[1]
Status September 9, 2026: contempt sanctions; appeal continues.[1]

State v. Sandoval / In re Stephen D. Aarons concerns attorney sanctions for an unverified ChatGPT-assisted brief in a New Mexico criminal appeal.[1]

September 9, 2026 order

The Supreme Court found Aarons in direct contempt after he admitted submitting fabricated witnesses, false testimony and misrepresented legal authority without verification. It ordered a $5,000 payment within 30 days, referred him for discipline and barred appearances before that court pending the disciplinary process. The court struck the briefs and appointed the public defender’s office. Its nonprecedential order leaves the criminal appeal pending.[1]

Reuters reported on September 11 that Aarons expressed remorse, saying he had used ChatGPT to summarize trial material and had not understood its capacity to fabricate facts. His explanation was a response to the sanctions, not a finding excusing the conduct.[2]

References

  1. ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 New Mexico Supreme Court, No. S-1-SC-40845, September 9, 2026, paragraphs 3–19.
  2. ↑ Mike Scarcella, Reuters via WSAU, September 11, 2026.
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