Courts on AI / Fabricated or misquoted citations

Hulse-Gibson v. Hulse

District Court of Appeal of Florida, Second District · State appellate courts · FL · 2026-07-08 · No. 2D2025-1144 · opinion

Fabricated or misquoted citations Self-represented litigants using AIgenerative AI

The Florida Second District Court of Appeal affirms orders against Cynthia Hulse-Gibson without comment. The panel separately cautions the self-represented appellant that her briefs contained mismatches among propositions, case names and citations, and warns that unverified generative-AI legal research can expose filers to sanctions.

Disposition: The court affirmed without comment and cautioned Cynthia Hulse-Gibson to verify generative-AI-assisted pro se filings.
Recorded conduct: A self-represented appellant filed briefs with mismatches among legal propositions, case names and reporter citations after apparent generative-AI use. — outcome: warning; actor: litigant in person
Canonical record: Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

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

We affirm the orders on appeal without comment. We write, however, to caution Cynthia Hulse-Gibson about using generative AI in any future pro se filings without verifying the accuracy of the results. Hulse-Gibson's briefs here are replete with mismatches involving the purported legal proposition, the case name, and the reporter citation. See Fletcher v. Experian Info. Sols., Inc., 168 F.4th 231, 233 (5th Cir. 2026) ("This problem [the misuse of generative AI] now often manifests as false quotes or statements of law attributed to real cases, rather than the more easily recognizable fake cases."). Those who use generative AI to assist with legal research and brief writing must exercise special care to validate the results before signing and filing their briefs; their failure to do so exposes them to potential sanctions.

Authorities cited in the passage: Fletcher v. Experian Information Solutions, Inc., 168 F.4th 231 (5th Cir. 2026) · Fla. R. Gen. Prac. & Jud. Admin. 2.515(d)(2) · Gleason v. Marcus, 51 Fla. L. Weekly D962 (Fla. 2d DCA May 13, 2026) · Gutierrez v. Gutierrez, 399 So. 3d 1185 (Fla. 3d DCA 2024)

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