On June 30, 2025, Judge Jeffrey A. Watkins of the Court of Appeals of Georgia issued his opinion for the case Nimat Shahid v Sufyan Esaam (Case number A25A0196) that was appealed by Ms. Nimat Shahid (Shahid) from a superior court (Georgia’s trial court) case involving a divorce.
Shahid argued that the superior court order was “void on its face,”1 because it relied on two factitious cases. Mr. Sufyan Esaam’s attorney, Ms. Diana Lynch (Lynch), did not address directly to Shahid’s assertions, but Judge Watkins noted that Lynch relied on four cases in Lynch’s Appellee’s Brief where “two of which appear to be fictitious, possibly ‘hallucinations’ made up by generative-artificial intelligence (‘AI’), and the other two have nothing to do with the proposition stated in the Brief.” (footnotes removed)2
After reviewing the superior court’s order, Judge Watkins determined that “both of the cases cited in the order denying her petition to reopen [did] not exist.”3 As such, Judge Watkins continued,
Because the order denying her motion to set aside the divorce decree has a defect apparent on its face, we cannot conduct any meaningful appellate review of the merits of Wife’s argument that the court lacked jurisdiction over her person. Accordingly, we vacate the order and remand for further proceedings consistent with this opinion.
The superior court is specifically directed to hold a new hearing on Wife’s motion to set aside the divorce decree. (footnotes removed)4
In addition, Judge Watkin imposed a $2,500 frivolous motion penalty on Lynch, in part due to Lynch’s failure to address Shahid’s assertions that the superior court relied on two factitious cases and Lynch’s Appelle’s Brief containing “11 bogus case citations.”5
Significance: This may have been the first instance of a U.S. state judge unintentionally relying on factitious court cases to issue a court order.
References:
Shahid v. Esaam, A25A0196 (Ga. Ct. App. 2025). PDF of Judge Watkin’s available here.
Court of Appeals of Georgia Docket Search for case number A25A0196. Link: https://www.gaappeals.us/wp-content/themes/benjamin/docket/results_one_record.php?docr_case_num=A25A0196