Courts on AI / Fabricated or misquoted citations

Christopher Gleason v. Julie Marcus

District Court of Appeal of Florida, Second District · State appellate courts · FL · 2026-05-13 · No. 2D2024-2688 · opinion

Fabricated or misquoted citations

On 2026-05-13, in Christopher Gleason v. Julie Marcus, District Court of Appeal of Florida, Second District warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities.

Disposition: The judgment was affirmed and Gleason was warned that any future briefs with fabricated authorities may be sanctioned.
Recorded conduct: Gleason’s pro se appellate brief contained numerous nonexistent authorities, fake quotations, and mischaracterized cases that appeared to be AI-generated. The court warned him about future sanctions. — 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.

His briefs cite numerous cases that do not exist, and they frequently quote case law for propositions that appear nowhere in the cases cited. We have cautioned on the dangers of using generative artificial intelligence before, see, e.g., Russell v. Mells, 426 So. 3d 913, 920 (Fla. 2d DCA 2025), and we again sound the alarm. “This technology is very good at sounding right, but less adept at being right,” and “blind reliance” on it is unwise, unacceptable, and sanctionable. See Gouveia v. Meridian Fin. Invs., LLC, No. 4D2025-0843, 2026 WL 816497, at *3 (Fla. 4th DCA Mar. 25, 2026) (Lott, J., concurring); see also Gutierrez v. Gutierrez, 399 So. 3d 1185, 1187–88 (Fla. 3d DCA 2024) (sanctioning pro se litigant for citing multiple nonexistent cases in his appellate briefs). We notify Mr. Gleason that future filings of this nature will not receive favorable treatment, and we remind all litigants—bothproseandrepresented—thattheymustensure the accuracy of their filings or risk the consequences. See Fla. R. App. P. 9.045(d); Fla. R. Jud. Admin.

Authorities cited in the passage: Russell v. Mells, 426 So · See Gouveia v. Meridian Fin. Invs · Gutierrez v. Gutierrez, 399 So

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document No matching official/primary copy located as of 2026-09-08 (checked flcourts-media.flcourts.gov, edca DCA document archive, storage.courtlistener.com). Official copy not obtained 2026-09-08: No matching official/primary copy located as of 2026-09-08 (checked flcourts-media.flcourts.gov, edca DCA document archive, storage.courtlistener.com) (checked flcourts-media.flcourts.gov, edca DCA document archive, storage.courtlistener.com). Re-coded from the document 2026-09-08 (independent second read).

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