Williams v. State (Ind. Ct. App.) AI-assisted transcript

What happened

In Williams v. State, Rashaan Williams appealed his conviction in Marion Superior Court for dealing in a controlled substance resulting in death. The appeal, No. 25A-CR-3041, challenged the admission of unrecorded statements to police and the sufficiency of the evidence. The appellate court worked from the official trial transcript, prepared by the trial court's reporter.

The transcript contained errors of several kinds. As summarized in the decision and in reporting, there were typos that changed the meaning of testimony, questions and objections; incorrect names for witnesses and attorneys; a State motion attributed to the trial court; an objection by Williams attributed to the bailiff; and the State's closing argument attributed to the trial court.

What the court did

In a memorandum decision in Williams v. State dated July 23, 2026, written by Judge Paul Felix, the court affirmed on both issues. In a footnote, the decision states that the transcript "is far from the best" and that "[b]ased upon the types of errors reviewed, it appears that generative artificial intelligence may have assisted with the preparation of this transcript. While AI can improve efficiency and be a productive tool for many professionals, it is incumbent upon those using such systems to proofread and ensure the accuracy of the generated product."

According to The Volokh Conspiracy, the court said the errors complicated but did not substantially impede its review. The decision does not identify the court reporter or any tool, and no sanction was reported.

Where it stands

The decision affirmed the conviction. The footnote was first reported by 404 Media. A linguist writing at Language Log questioned the court's inference, arguing that misattributed speakers and meaning-changing typos are characteristic of speech-to-text and speaker-identification software rather than of generative AI. The source of the errors therefore rests on the court's inference and has not been confirmed.

The obligation it engaged

A transcript is a primary source. Appellate courts, counsel and experts all build on it, and each assumes it records what was said and who said it. The footnote describes output adopted without being checked against the recording it was meant to represent. That is Clause 4 of the Expert Record Standard, checkability before adoption, and Clause 3, independent authority: the words attributed to a speaker should be confirmed against the audio, not accepted on the system's rendering.

For experts, the matter carries a second point. An expert who relies on a transcript to form an opinion is relying on a document that may itself have passed through a system. Where attribution matters to the opinion, the recording is the independent source to confirm it against.

The footnote places the duty on the person who uses the system, not on the system. That allocation matches the Standard. A court reporter who certifies a transcript, like an expert who signs a report, adopts every word of it, and the certification is only as good as the comparison that preceded it.

Sources

• Court of Appeals of Indiana · July 23, 2026
  Rashaan Williams v. State of Indiana, Memorandum Decision, No. 25A-CR-3041
• 404 Media · July 23, 2026
  A Court Reporter Submitted AI-Generated Errors in Official Court Transcript, Judge Says
• Reason (The Volokh Conspiracy) · July 25, 2026
  Court Notes Apparent AI-Generated Errors in Court Reporter's Transcript
• Language Log · July 2026
  "Generative AI" != speech-to-text, diarization etc.

What could not be confirmed

The court reporter and the transcription tool are not identified. Whether generative AI, as opposed to conventional speech-to-text software, produced the errors is the court's inference and is disputed by at least one commentator. One secondary source dates the decision July 24, 2026; the decision itself is dated July 23, 2026.