Laurie Ibach and Mark Stewart v. Bruce Stewart, individually, as Trustee of the Betty L. Stewart Living Trust, and as Trustee of the Edward T. Stewart Living Trust

── Laurie Ibach and Mark Stewart v. Bruce Stewart, individually, as Trustee of the Betty L. Stewart Living Trust, and as Trustee of the Edward T. Stewart Living Trust ── Court: Supreme Court of Alabama Date: April 24, 2026 Author: Chris McCool Category: General Rel: April 24, 2026 Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter. SUPREME COURT OF ALABAMA OCTOBER TERM, 2025-2026 _________________________ SC-2025-0106 _________________________ Laurie Ibach and Mark Stewart v. Bruce Stewart, individually, as Trustee of the Betty L. Stewart Living Trust, and as Trustee of the Edward T. Stewart Living Trust Appeal from Mobile Circuit Court (CV-24-901773) McCOOL, Justice. SC-2025-0106 Laurie Ibach and Mark Campbell appeal the Mobile Circuit Court's entry of a summary judgment in favor of their uncle, Bruce Stewart. This case concerns a family dispute over Bruce's alleged fiduciary duties as trustee of the Betty L. Stewart Living Trust and the Edward T. Stewart Living Trust. At the outset, we note that W. Perry Hall, counsel for Laurie and Mark, filed briefs in this appeal that contain numerous invalid, inaccurate, and/or irrelevant citations to legal authorities. They appear to be artificial-intelligence ("AI") "hallucinations," i.e., fake authorities created by an AI system. Because those briefs are grossly deficient under the Alabama Rules of Appellate Procedure, we dismiss the appeal. Further, pursuant to our inherent authority to conduct the proceedings before us in an effective manner and Rule 38, Ala. R. App. P., we find that Hall's conduct is so egregious as to warrant sanctions as set forth below. I. Facts and Procedural History Although we dismiss the appeal for failure to follow our rules of procedure, we set forth the following facts and procedural history to provide context for our ruling. 2 SC-2025-0106 Laurie and Mark are Edward Stewart's and Betty Stewart's grandchildren, and Bruce is Edward's and Betty's son. The Betty L. Stewart Living Trust and the Edward T. Stewart Living Trust were effectively identical, the only substantive difference between the two trusts was the swapping of names, i.e., where Betty's trust had Edward's name listed, Edward's trust had Betty's name listed, and vice versa. Both trusts stated that they were governed by the substantive law of the State of Illinois. Each trust was fully revocable by the settlor during his or her life and made irrevocable upon the settlor's death. Each trust provided that the trust would be split into a "Marital Share" and a "Non-Marital Share" upon the death of the settlor. Edward died in 2009, before Betty, so his trust became irrevocable at that time, and it was split into the marital and nonmarital shares. Betty's trust provided her with the right to amend her trust in writing. Betty used that power to make multiple amendments. Originally, the trust named Betty's children, Bruce and Patricia Stewart Campbell, who was Laurie's and Mark's mother, as equal remainder beneficiaries of the trust. The trust provided that if either child predeceased Betty, the trustee would distribute that child's share to his or her descendants upon 3 SC-2025-0106 Betty's death. However, Patricia died in September 2017, leaving Bruce as the only surviving child of Betty. In an amendment, Betty directed her successor trustee to distribute 100% of the net trust estate to Bruce. Edward's trust provided Betty with a general power of