A Wisconsin prosecutor just got a real-world lesson in what happens when AI enters a courtroom.
A Wisconsin prosecutor faced consequences after a court filing was found to contain fabricated legal citations generated with the help of artificial intelligence, according to the Milwaukee Journal Sentinel.
Kenosha County District Attorney Xavier Solis was sanctioned by Circuit Court Judge David Hughes after the judge struck one of Solis’ written submissions in a case involving two defendants. The judge determined that the document relied on AI tools without disclosure and cited court cases that did not exist. Court records indicate Solis acknowledged he had not informed the court that AI was used in preparing the filing.
Judge Hughes criticized the use of what he called “hallucinated and false citations,” according to Wisconsin Public Radio. Kenosha County court policy requires anyone using AI to assist in preparing legal documents to disclose the tool used along with its “limitations or potential biases.” The policy also states that the person submitting the filing must verify the accuracy and appropriateness of any AI-generated content.
The issue surfaced during a Feb. 6 hearing involving brothers Christain Garrett, 26, and Cornelius Garrett, 32. The two men had faced a combined 74 charges, including numerous felony counts connected to alleged break-ins of trucks and trailers. After nearly two years, defense attorneys moved in August 2025 to dismiss the case, arguing prosecutors had not produced sufficient evidence.
Judge Hughes dismissed all charges against both men without prejudice, meaning they could be refiled. Defense attorney Michael Cicchini said the dismissal was based on the judge’s review of the earlier evidence rather than the AI-related filing, noting that the court found no probable cause that a crime had been committed.
In a statement, Solis emphasized that the dismissal “was based on the court’s independent review of the preliminary hearing records, not on AI.” He added that the judge addressed the AI issue separately from the probable-cause decision. Solis also said his office has since reviewed and strengthened internal practices, including verifying citations in future filings.
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