Johnson v. Dunn (Butler Snow)

What happened

In Johnson v. Dunn, Frankie Johnson, an incarcerated man, brought a civil rights action against former Alabama Department of Corrections Commissioner Jefferson S. Dunn and other officials. Butler Snow LLP represented the defendants. The firm also held substantial state contracts for prison litigation, as the Alabama Reflector reported.

In May 2025 the firm filed a motion for leave to depose an incarcerated person and a motion to compel discovery. Together the 2 motions contained 5 hallucinated citations (references to authority that does not exist or does not support the stated proposition). The court's opinion found that partner Matthew B. Reeves "performed a search [on ChatGPT] to identify supporting case law" and inserted the results without checking them. The court found that William J. Cranford "drafted, signed, and personally filed both motions" and that practice group leader William R. Lunsford "allowed Mr. Cranford to use his name in the signature block on both motions." One of the 5 citations was to a real case that did not support the proposition; the others did not exist or pointed to unrelated cases.

The firm had a written policy requiring "written permission from the appropriate Practice Group Leader to use this new technology as a secondary research tool." The opinion notes that Reeves admitted he violated that policy.

What the court did

On July 23, 2025, Judge Anna M. Manasco issued a sanctions opinion in Johnson v. Dunn. Its decretal language reads: "the court PUBLICLY REPRIMANDS Mr. Reeves, Mr. Cranford, and Mr. Lunsford for making false statements to the court; ORDERS publication of this order to effectuate that reprimand; DISQUALIFIES them from further participation in this case; and REFERS this matter to the Alabama State Bar and other applicable licensing authorities."

The court declined to impose a fine. It wrote that "fines do not account for the extreme dereliction of professional responsibility that fabricating citations reflects, nor for the many harms it causes." Butler Snow itself was released without sanction, as were 2 other firm lawyers whose names appeared on the filings. The opinion is reported at 792 F.Supp.3d 1241.

Where it stands

The 3 lawyers were removed from Johnson v. Dunn. The order did not bar the firm itself from continuing to represent the defendants. The outcome of the Alabama State Bar referral had not been reported in the sources reviewed as of September 11, 2026.

The obligation it engaged

The conduct engaged Clause 3 of the Expert Record Standard (independent authority). A search run in a chat system returned case names, and those names went into a filing without being pulled from a reporter. The clause does not turn on the tool; it turns on whether each authority was confirmed against an independent source before use.

The matter also shows the limit of policy without procedure. The firm's policy existed and was not applied to these filings. The Standard places the duty on the professional who signs, and it is met only by a check performed on each item. The supervising lawyers were sanctioned alongside the drafter, which reflects that the signature attests to that check.

Sources

• U.S. District Court, N.D. Ala. (copy hosted by UC Berkeley School of Law) · July 23, 2025
  Johnson v. Dunn, 792 F.Supp.3d 1241 (2025)
• Alabama Reflector · July 24, 2025
  Federal judge removes attorneys from Alabama DOC lawsuit after AI fabricated citations

What could not be confirmed

The Alabama State Bar's handling of the referral was not found.