In Laurie Ibach and Mark Stewart v. Bruce Stewart, individually, as Trustee of the Betty L. Stewart Living Trust, and as Trustee of the Edward T. Stewart Living Trust, SC-2025-0106, 2026 WL 1110659 (April 24, 2026), the Court (McCool, J.; Shaw, Wise, Bryan, and Parker, JJ., concurring; Cook, J., concurring specially with opinion; McCool, J., concurring specially with opinion, which Stewart, C.J., joins; and Sellers and Mendheim, JJ., concurring in part and dissenting in part, with opinions) dismisses the appeal and imposes sanctions on appellants’ counsel due to grossly deficient appellant briefs containing fake, misquoted, irrelevant, and artificial-intelligence (“AI”) “hallucination” citations.
In July 2024, Laurie Ibach and Mark Stewart sued their uncle, Bruce Stewart, in the Mobile Circuit Court, alleging he exerted undue influence over their grandmother and wrongfully deprived them of an expected inheritance. Id. at *2. Bruce moved for summary judgment, arguing that the claims were time-barred and, in part, not legally recognized under Alabama law. Id. The circuit court granted summary judgment in Bruce’s favor, holding that the plaintiffs’ claims were time-barred. Id. The plaintiffs appealed. Id.
On appeal, the Court dismisses the appeal due to the plaintiffs’ counsel’s submission of briefs containing numerous fabricated, misquoted, or irrelevant citations to legal authorities—many generated by artificial intelligence. Id. at *12. The Court finds the submissions so deficient that they fail to comply with appellate rules and render meaningful review impossible. Id. The Court also denies plaintiffs’ motion to file supplemental briefs, as the appellate rules do not provide a party who has filed an insufficient brief the opportunity to file another, and to allow so would be a “second bite at the apple” that would be “fundamentally unfair to the opposing party and to the efficient administration of justice.” Id. Importantly, the plaintiffs’ attorney addressed his use of improper authorities in a single footnote in his reply brief and stated that the mistake would not reoccur. Id. at *5. However, the entire reply brief, including that very footnote, included nonexistent and misquoted authorities. Id. at *5-6.
Pursuant to the Court’s inherent authority to conduct proceedings in an effective manner and Ala. R. App. P. 38, the Court deems the appeal frivolous due to its manifest insufficiency and imposes sanctions on the offending attorney. Sanctions include monetary penalties to be paid to the opposing party, referral to the state bar, and a prohibition on filing anything with the Court unless an attorney in good standing with the Alabama State Bar also signs the filing. Id. at *12-13.