Courts on AI / Fabricated or misquoted citations
Gouveia v. Meridian Financial Investments, LLC
District Court of Appeal of Florida, Fourth District · State appellate courts · FL · · No. 4D2025-0843 · opinion
On 2026-03-25, Florida Fourth District Court of Appeal cautioned the self-represented appellant, in prose and a limerick, that future briefs with nonexistent cases may invite sanctions. A self-represented party submitted an appellate brief with fabricated or nonexistent authorities and mischaracterized authorities, including In re Kenney, 2025-0389.
- Disposition
- The court affirmed and wrote separately to caution about apparent AI use in briefing.
- Recorded conduct
- The pro se appellant used authorities that were inapplicable or did not support the propositions asserted, in briefing that appeared to be written by an LLM. — 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.
• AI Spotted There once was a litigant pro se, Who let an AI lead the way. It briefed every claim, Cited cases—by name, That vanished by morning’s next day. Limerick on Pro Se Parties Using Artificial Intelligence (on file with the Fourth District Court of Appeal) (generated by ChatGPT 5.2). It appears to us the defendant used a large language model (LLM) 1 to write his briefs. Popular LLMs include OpenAI’s ChatGPT, Google’s Gemini, and Microsoft’s Copilot. See In re Kenney, 2025-0389 (La. App. 5 Cir. 10/23/25), 422 So. 3d 905, 912 n.5. Technology, specifically artificial intelligence, is a marvel of the age we live in. It is an important and productive tool, but left unchecked for accuracy and legitimacy, it can be a plague upon the judicial system, creating more problems than it solves, and resulting in violation of the rules of appellate procedure. As Judge Forst reminded us: An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system [….] Many harms flow from the submission of fake opinions [….] These include wasting the opposing party’s time LLMs “are [artificial intelligence] systems that aim to model language, sometimes using millions or billions of parameters[.]” See LAURIE HARRIS, CONG. RSCH. SERV., IF12426, GENERATIVE ARTIFICIAL INTELLIGENCE: OVERVIEW, ISSUES,
Authorities cited in the passage: In re Kenney, 2025-0389
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