Tennessee Attorney Censured for AI-Generated False Citations

TN Board of Professional Responsibility

Filed March 30th, 2026

Detected March 31st, 2026

Summary

The Tennessee Board of Professional Responsibility publicly censured attorney Matthew Wayne Willis for submitting an AI-generated reply brief to the Armed Services Board of Contract Appeals containing over 70% fictitious legal citations. The Board found Willis violated Rules 1.3 (diligence), 5.3 (supervision of nonlawyer assistants), and 8.4 (misconduct) by failing to verify AI outputs and adequately supervise his paralegal. A Public Censure serves as a formal rebuke and warning but does not restrict the attorney's license to practice.

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What changed

Matthew Wayne Willis, a Tennessee-licensed attorney (BPR #024803), received a Public Censure on March 30, 2026, after filing an AI-generated reply brief with the Armed Services Board of Contract Appeals. The Board's investigation revealed that over seventy percent of the citations in the brief were fictitious, and Willis had failed to verify the accuracy of the AI-generated content before filing. Willis claimed he relied on his paralegal to perform citation verification but admitted he did not confirm the paralegal completed this task. The Board determined Willis violated Rules 1.3 (Diligence), 5.3 (Responsibilities Regarding Nonlawyer Assistants), and 8.4 (Misconduct).

Tennessee attorneys and law firms must immediately implement verification protocols for any work product prepared with AI assistance, ensuring all citations are manually checked against primary sources before filing. Attorneys must also review their supervisory obligations under Rule 5.3, confirming that nonlawyer assistants are properly directed and that their work is adequately supervised. Failure to verify AI-generated legal work constitutes professional misconduct regardless of reliance on support staff.

What to do next

Implement mandatory verification procedures for all AI-generated citations and legal authorities before filing
Update office practices to require attorney-level review of all AI-generated work product prior to submission
Review and strengthen supervisory protocols for nonlawyer assistants under Rule 5.3

Penalties

Public Censure - a formal rebuke and warning that does not affect the attorney's ability to practice law

Source document (simplified)

BOARD OF PROFESSIONAL RESPONSIBILITY

OF THE SUPREME COURT OF TENNESSEE

10 CADILLAC DRIVE, SUITE 220 BRENTWOOD, TENNESSEE 37027 TELEPHONE: (615) 361-7500 (800) 486-5714 Website: www.tbpr.org RELEASE OF INFORMATION RE: MATTHEW WAYNE WILLIS, BPR #024803 CONTACT: MAUREEN F. HUGHES BOARD OF PROFESSIONAL RESPONSIBILITY 615-361-7500 March 30, 2026 DYER COUNTY LAWYER CENSURED On March 30, 2026, Matthew Wayne Willis, an attorney licensed to practice law in Tennessee, received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court. Mr. Willis was representing a client before the Armed Services Board of Contract Appeals. Mr. Willis personally used Artificial Intelligence (AI) to aid him in the preparation of a reply brief he filed with the Armed Services Board of Contract Appeals. The Court found that after reviewing the reply brief, over seventy percent of the citations were fictitious, and Mr. Willis took no action to check the accuracy of these citations. Mr. Willis stated that he believed a paralegal in his office performed a full citation check including verifying references to the technical record, transcript, and legal authorities. Mr. Willis failed to verify that his paralegal checked the citations before filing the reply brief. Mr. Willis failed to act with diligence and his conduct was prejudicial to the administration of justice. Additionally, Mr. Willis failed to exercise managerial authority over his paralegal. By these acts, Mr. Willis has violated Rules of Professional Conduct 1.3 (diligence), 5.3 (responsibilities regarding nonlawyer assistants), and 8.4 (misconduct) and is hereby Publicly Censured for these violations. A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability to practice law.

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