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Courts on AI / Fabricated or misquoted citations

Straub v. Henderson

District Court of Appeal of Florida · State appellate courts · FL · · 2026 WL 516317 · No. No. 2D2024-1772, 2025 · opinion

Florida District Court of Appeal on 2026-02-25 in Straub v. Henderson found the self-represented party's appellee brief contained one citation defect involving nonexistent authorities. The court affirmed the judgment while identifying the defective authorities in the appellate briefing in the challenged filing before resolving the pending matter.

Disposition
The court affirmed the judgment while identifying the defective authorities in the appellate briefing.
Recorded conduct
The self-represented party's appellee brief contained one citation defect involving nonexistent authorities. — outcome: other; 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.

NOTICE: THIS OPINION HAS NOT BEEN RELEASED *1 Affirmed. See Clerk of Ct. & Comptroller for 13th Jud. FOR PUBLICATION IN THE PERMANENT Cir., Hillsborough Cnty. v. Rangel, No. 2D2024-1772, 2025 LAW REPORTS. UNTIL RELEASED, IT IS WL 2486314, at *2 (Fla. 2d DCA Aug. 29, 2025) (“[T]he SUBJECT TO REVISION OR WITHDRAWAL. dangers of relying on generative artificial intelligence have been discussed in the media, in legal publications, and in District Court of Appeal of Florida, Second District. court opinions.”); Takefman v. Pickleball Club, LLC, 418 So. 3d 826, 827 (Fla. 3d DCA 2025) (“We write, however, to CHRISTOPHER STRAUB, Appellant, address an issue of growing concern—the proliferation of v. fake or hallucinated case citations in court filings.... Opposing MELISSA HENDERSON, as Successor counsel, and the court, should not have to parse case citations Trustee of the Margaret McShane Revocable and parentheticals to discern whether cases exist, and if so, Trust Dated March 24, 2016, Appellee. if they stand for the propositions asserted.”), reh'g denied (Sept. 11, 2025); Goya v. Hayashida, 418 So. 3d 652, 655 No. 2D2025-1787 (Fla. 4th DCA 2025) (“An attempt to persuade a court or | oppose an adversary by relying on fake opinions is an abuse February 25, 2026 of the adversary system.” (quoting Park v. Kim, 91 F.4th 610, Appeal from the Circuit Court for Hillsborough County; 615 (2d Cir. 2024))); see also Gutierrez v. Gutierrez, 399 So. Emily A. Peacock, Judge. 3d 1185, 1187-88 (Fla. 3d DCA 2024) (dismissing pro se appellant's appeal and imposing sanctions for filing briefs that Attorneys and Law Firms contained “fictitious and nonexistent case law”). Christopher Straub, pro se. Marc C. Mann of Berlin Patten Ebling PLLC, Tampa, for LUCAS, C.J., and NORTHCUTT and ATKINSON, JJ., Appellee. Concur. --- So.3d ----, 2026 WL 516317 (Mem)

Authorities cited in the passage: Hillsborough Cnty. v. Rangel, No. 2D2024-1772, 2025 · Takefman v. Pickleball Club · Goya v. Hayashida · Park v. Kim · Gutierrez v. Gutierrez

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub