Courts on AI / Fabricated or misquoted citations
Eclectic Synergy, LLC v. Seredin
District Court of Appeal of the State of Florida, Fourth District · State appellate courts · FL · · No. No. 4D2026-0781 · opinion
On 2026-05-27, in Eclectic Synergy, LLC v. Seredin, District Court of Appeal of Florida, Fourth District ordered counsel to show cause why sanctions should not issue for an apparently AI-generated emergency stay motion. Counsel filed a response using several nonexistent or hallucinated authorities and authorities used for propositions they did not support.
- Disposition
- The court affirmed, sanctioned counsel by referral to The Florida Bar, and denied rehearing motions.
- Recorded conduct
- Counsel John O’Hara filed a certiorari petition that appeared AI-generated, misstated law, and cited a nonexistent Florida Masek case; he said he relied on a paralegal and denied using AI. The court referred him to The Florida Bar. — outcome: regulatory referral; actor: lawyer
- 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 denied the “emergency” motion for stay,1 and issued an order requiring counsel to show cause why sanctions should not be imposed because the petition appears AI-generated and raises frivolous arguments, misstates the law, and cites non-existent caselaw. Fla. R. App. P. 9.410(a). As an example, we quoted page 5 of the petition, which argues: Florida appellate courts have recognized that certiorari relief is appropriate where an order lacks sufficient findings to permit meaningful review. See Citigroup Global Mkts., Inc. v. Masek, 982 So. 2d 1231 (Fla. 4th DCA 2008). No such case exists in Florida. The citation links to Liberty Transportation, LLC v. Banyan Air Services, Inc., 982 So. 2d 1231 (Fla. 4th DCA 2008), which does not support this argument and is irrelevant to this proceeding. Additionally, we noted that the petition cites generally to several other cases for legal propositions that the cited cases do not actually represent.2 The petition also cites inapplicable second-tier certiorari cases. 1 The allegation of an “emergency” was frivolous. ... Counsel has responded to our order to show cause and argues that he was not trying to intentionally mislead this Court and that his citation was referring to an Ohio appellate court decision. He does not acknowledge using AI and alleges that he relied on a paralegal for legal research. The false citation was allegedly a “transcription error” and “clerical mistake.” The response states: During multi-jurisdictional research (to find exact match not found in Florida), the Ohio decision was inadvertently assigned the Florida Fourth District Court of Appeal – thereby making the citation a clear transcription error during final compilation. The response argues that “the citation error ...
Authorities cited in the passage: Inc. v. Masek, 982 So · LLC v. Banyan Air Services