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Courts on AI / Fabricated or misquoted citations

Samantha Roussell v. The Bank of New York Mellon

District Court of Appeal of Florida · State appellate courts · FL · · 2026 WL 681054 · No. No. 4D2025-1309 · opinion

Florida District Court of Appeal on 2026-03-11 in Samantha Roussell v. The Bank of New York Mellon found the self-represented party's appellee brief contained two citation defects involving mischaracterized authority, incorrect statutory or rule text, defective exhibits or submissions. The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's appellee brief contained two citation defects involving mischaracterized authority, incorrect statutory or rule text, defective exhibits or submissions. — 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.

FOR PUBLICATION IN THE PERMANENT record, we affirm on the merits without discussion. We write, LAW REPORTS. UNTIL RELEASED, IT IS however, to address our concerns with the purported legal SUBJECT TO REVISION OR WITHDRAWAL. authority upon which the appellant relied in her brief. The appellant cited thirteen different cases that do not exist. We District Court of Appeal of Florida, Fourth District. expressly disregard these hallucinated cases. Furthermore, the appellant cited nine different cases that do exist, but do SAMANTHA ROUSSELL, Appellant, not stand for the proposition described by the appellant. A v. party, whether represented by counsel or proceeding pro se, THE BANK OF NEW YORK is responsible for the content of any submission to the court. MELLON, ETC., et al., Appellees. If a party chooses to use artificial intelligence to assist in the preparation of a brief, it must do so with care and take No. 4D2025-1309 steps to ensure the accuracy of any submissions to the court. | “While we decline to do so here, this court has the authority to [March 11, 2026] sanction appellant under Florida Rule of Appellate Procedure Appeal from the Circuit Court for the Seventeenth Judicial 9.410(a) for failure to comply with Florida Rule of Appellate Circuit, Broward County; Gary Michael Farmer, Jr., Judge; Procedure 9.210(c).” Friend v. Serpa, 425 So. 3d 51 (Fla. 4th

Authorities cited in the passage: Friend v. Serpa

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