A Wisconsin prosecutor just got a real-world lesson in what happens when AI “hallucinations” enter a courtroom. Kenosha County District Attorney Xavier Solis was sanctioned after a judge tossed out one of his filings for relying on undisclosed artificial intelligence and bogus legal citations, the Milwaukee Journal Sentinel reports. Circuit Court Judge David Hughes said Solis’ written response in a case involving two defendants used AI tools without telling the court and cited cases that simply didn’t exist. The court record says Solis acknowledged he hadn’t revealed his use of AI.
Court records show that Hughes slammed Solis for using “hallucinated and false citations,” WPR reports. Kenosha County court policy calls for anybody using AI to prepare documents to submit a disclosure detailing the AI tool and its “limitations or potential biases.” The policy says the person making the filing needs to ensure they have “verified the accuracy and appropriateness of any AI-generated content in the filed document.”
The Feb. 6 hearing involved brothers Christain Garrett, 26, and Cornelius Garrett, 32, who had faced a combined 74 charges, including dozens of felonies tied to alleged break-ins of trucks and trailers. The case had dragged on for nearly two years when defense attorneys moved to dismiss in August 2025, arguing prosecutors hadn’t produced enough evidence. Hughes dismissed all charges against both men without prejudice, meaning they could be brought again. Defense lawyer Michael Cicchini said the dismissal was rooted in the judge’s review of the earlier evidence, not the AI-tainted brief, adding that Hughes found no probable cause the crime had been committed.
Solis, a former defense attorney who took office as DA in January 2025 with no prior prosecutorial experience, stressed in a statement that the dismissal “was based on the court’s independent review of the preliminary hearing records, not on AI.” He said the judge dealt with his AI use separately from the probable-cause ruling. Solis added that his office has now “reviewed and reinforced” its internal practices, including checking future citations for accuracy.
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