Gouldy v. Chiasson

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

This case demonstrates a growing problem in Florida’s appellate courts. The recent change in jurisdiction has given intermediate appellate courts jurisdiction to hear appeals from county court cases. The result has been that the amount of pro se appeals has significantly increased. Initially, the appellate courts were able to expeditiously handle the county court appeals.

Recently, however, it appears that many pro se litigants, in both county and circuit courts, are using artificial intelligence platforms to generate appellate briefs and motions. While the prose in these filings is generally readable, many AI-generated submissions contain phantom authority, misstatements of the record, and fabricated quotations. Pro se litigants are not governed by the ethical rules with which licensed attorneys must comply. Because a principled appellate court must examine the issues raised by the parties, digging into AI-generated filings consumes valuable time that could be better spent on other cases.

We have observed:

“The submission of fictitious or fabricated case law—whether the product of carelessness, misunderstanding, or reliance on generative artificial-intelligence tools—is sanctionable.” Francois v. Vive Fin., LLC, 51 Fla. L. Weekly D500 (Fla. 4th DCA Mar. 18, 2026); see also Goya v. Hayashida, 418 So. 3d 652, 656 (Fla. 4th DCA 2025); Gutierrez v. Gutierrez, 399 So. 3d 1185, 1188 (Fla. 3d DCA 2024). This includes citations to cases that do not stand for what is argued.

Gouldy’s arguments in this appeal are either unpreserved, inadequately briefed, or wholly meritless. She raised fifteen issues, some with sub-issues. To the extent any of her issues may contain a shred of arguable merit (e.g., the unpreserved apportionment argument), they are swamped by the sea of frivolous arguments that dominate her initial brief. Her initial brief cites a nonexistent case, misrepresents the record, fabricates multiple quotations from actual legal decisions, and otherwise relies upon cases that do not support the propositions for which they are cited.

Authorities cited in the passage: Francois v. Vive Fin., LLC, 51 Fla. L. Weekly D500 (Fla. 4th DCA Mar. 18, 2026) · Goya v. Hayashida, 418 So. 3d 652 (Fla. 4th DCA 2025) · Gutierrez v. Gutierrez, 399 So. 3d 1185 (Fla. 3d DCA 2024)