Wisconsin judge sanctions DA for false AI citations, dismisses 74 charges

A judge threw out a court filing submitted by Kenosha County District Attorney Xavier Solis after finding it relied on undisclosed artificial intelligence and contained made-up legal citations.

Kenosha County Circuit Court Judge David Hughes sanctioned Solis during a Feb. 6 hearing involving two men who were facing a combined 74 criminal charges, including 38 felonies. Hughes struck Solis’ written response after finding it used AI without disclosure and relied on “hallucinated,” false legal citations.

AI “hallucinations” refer to made-up or incorrect information that an AI system, such as ChatGPT, presents as if accurate.

The court record states Solis admitted he did not disclose his use of AI.

Hughes dismissed all the charges against the two defendants at the hearing.

The defendants, 26-year-old Christain Garrett and 32-year-old Cornelius Garrett, were charged in 2023 with multiple felony counts tied to break-ins of trucks and trailers, along with numerous misdemeanor counts of criminal damage to property, according to court records.

The cases remained open for nearly two years, with repeated status conferences and attorney changes, before the defense moved to dismiss them in August 2025, arguing prosecutors never presented sufficient evidence to move the cases forward.

The judge ordered Solis to file a brief arguing against that motion.

Defense attorney Michael Cicchini, who represented Cornelius Garrett, said the judge’s decision to dismiss the charges was based on the underlying evidence presented earlier in the case – and not on Solis’ use of AI in his brief.

“In other words, the judge found that there was not probable cause that the defendant committed a crime,” said Cicchini.

The original charges were filed under the previous district attorney, not Solis.

All of the charges against the pair are now dismissed without prejudice, meaning they could be refiled. Brenda VanCuick, attorney for Christain Garrett, did not immediately respond to requests for comment Feb. 9.

In a statement to Public Investigator, Solis said the judge’s decision to dismiss was “based on the court’s independent review of the preliminary hearing records, not on AI.” Solis said the judge addressed his filing and use of AI separately.

“Our office takes accuracy, candor, and disclosure obligations seriously,” Solis said in the statement. “We have reviewed and reinforced our internal practices to ensure clarity and reliability in future filings, including verification of citations.”

The ruling adds to a growing record of courtroom setbacks under Solis. Since taking office, his administration has faced extensive turnover.

A former criminal defense attorney who had never worked as a prosecutor, Solis was sworn in as district attorney in January 2025 after narrowly winning the race with about 52% of the vote.