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 WL 1311959 · No. 2D2024-2688 · order
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 court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
- Recorded conduct
- A self-represented appellant filed an appellate brief using quotations that did not appear in the cited source, numerous nonexistent or hallucinated authorities, and authorities used for propositions they did not support. — 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
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