Clayton County District Attorney's Office
Order denying Hannah Renee Payne's motion for new trial, Superior Court of Clayton County, 12 September 2025 — prepared by ADA Deborah Leslie
Sanctioned · 5 May 2026
What was fabricated
Citations to cases that do not exist, carried in a court's own order. The Supreme Court of Georgia found that the State's filings and the trial court's order 'contain multiple case citations which either do not exist, or which exist but do not support the propositions of law', and that the order 'contains numerous fictitious or misattributed case citations'. The opinion describes the order as 'largely prepared by ADA Leslie' and records that the order 'reflects that ADA Leslie prepared that order'. Footnote 2: Bryant v. State 'appears not to exist at all'; Hamm v. State does not support its cited proposition. THE COURT GIVES NO SINGLE TOTAL: nine citations in the trial court's order that do not exist or do not support the propositions; 12 further cases in the State's trial-court briefing that ADA Leslie acknowledged were AI-generated, unverified and unsupportive; and nine authorities in the State's 16 December 2025 appellate brief on which she withdrew reliance. THE COURT MAKES NO FINDING ON FABRICATED QUOTATIONS — 'case quotations that do not accurately reflect' is ADA Leslie's own language in her withdrawal, not the Court's.
What happened as a result
Supreme Court of Georgia, decided 5 May 2026: (1) the trial court's 12 September 2025 order denying the motion for new trial is VACATED and the case REMANDED with instructions that the new order contain no fictitious or misattributed citations and not be prepared by counsel for either party; (2) ADA Deborah Leslie's privilege to practise before the Supreme Court of Georgia is SUSPENDED FOR SIX MONTHS, reinstatement conditional on 12 hours of continuing legal education beyond the regular requirement, covering ethics, brief writing and the proper use of AI software; (3) ADA Leslie and the Clayton County District Attorney's Office are ADMONISHED for failing to verify citations; (4) the Motion to Clarify is granted and the State must produce related communications with the trial court. No monetary sanction. No referral to the State Bar or the Judicial Qualifications Commission — footnote 4 says only that the sanctions are case-specific and do not affect disciplinary proceedings others may bring. Justices LaGrua and Colvin concur in part and dissent in part, and only as to admonishing the elected district attorney.
Sources
- https://www.gasupreme.us/wp-content/uploads/2026/05/s26a0459.pdf
- https://caselaw.findlaw.com/court/ga-supreme-court/118328739.html
- https://www.ajc.com/news/2026/03/clayton-prosecutor-admits-using-ai-in-filings-flagged-by-chief-justice/
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