By Bill Hartzer · Published · How this site is researched
What happened
In a paternity matter in Stephens County, Oklahoma, Associate District Judge Lawrence M. Wheeler issued an order on a motion requesting a psychological evaluation and mental health testing assessment. The order states that the court conducted its own legal research.
According to reporting by Reuters and the Volokh Conspiracy, the judge used ChatGPT for that research, and the resulting order contained two citations to cases that do not exist.
The order also warned that filings of similar character lacking factual or legal basis might be subject to further appropriate sanctions, including attorneys' fees and costs, under 12 O.S. section 2011.
What followed
Claims against Judge Wheeler were referred to the office of Oklahoma Attorney General Gentner Drummond. The claims included, beyond the fabricated citations, allegations that he offered to amend the order in exchange for dismissal of a writ, and that he eavesdropped on jury deliberations.
Reuters reported in early September 2026 that the Attorney General's office reviewed the claims and determined it would not pursue them further. No discipline was imposed.
Where it stands
The order stands as issued. The Attorney General's determination was reported on or about September 9, 2026. Whether any separate judicial conduct proceeding exists was not located as of September 17, 2026.
The obligation it engaged
The conduct engaged Clause 3 of the Standard, independent authority, in the setting where the failure carries furthest. A citation in a party's brief can be caught by the other side. A citation in a judge's order arrives with the authority of the court, and whoever reads it next is entitled to rely on it.
The outcome is the part worth recording. Nothing happened. Read with Phillips v. Parlade, in which judicial immunity barred a damages claim premised on a judge's alleged reliance on a system, and with Henry County Schools v. Grant, in which an appellate court reversed but imposed no sanction, a pattern is visible: the accountability mechanisms that reach lawyers and experts reach judges weakly, if at all.
The relevance to an expert is not comfort. It is the reverse. The asymmetry means an expert should expect no corresponding latitude, and should assume that the record of his own method will be examined by a standard no one is applying to the bench.
Sources
- Reason (The Volokh Conspiracy) · September 14, 2026
Oklahoma Judge's Ruling Contained AI Hallucinations - Damien Charlotin · September 17, 2026
AI Hallucination Cases database
What could not be confirmed
The only copy of the order located is a third-party annotated version bearing another organization's commentary header, and it is not treated here as the order of record. The clean official copy should be obtained from the Stephens County court clerk. The order is file-stamped November 17, 2025 and signed November 19, 2025. A case database lists this matter under a caption that does not match the caption on the document obtained; the discrepancy is unresolved. The Attorney General's determination is reported and no written determination was located.
About this entry
The primary document had not been located when this entry was checked, so it rests on the reporting listed above. The entry for Judge Wheeler (Oklahoma) fabricated citations records conduct and what the tribunal did. It does not characterize a holding and it is not legal advice. Last checked September 17, 2026. More matters like this one are collected under judges, courts and AI. If something here is out of date, write to [email protected].