Courts on AI / Fabricated or misquoted citations
Avery v. Beauzil
District Court of Appeal of the State of Florida, Fourth District · State appellate courts · FL · · No. Nos. 4D2026-0406; 4D2026-0921 · order
On 2026-05-27, in Robert Hinton Avery v. Danielle Beauzil, District Court of Appeal of Florida, Fourth District barred the appellant from future pro se filings in the case unless signed by a Florida Bar member. A self-represented appellant filed a brief using nonexistent or hallucinated authorities, authorities used for propositions they did not support, and a nonexistent.
- Disposition
- The court imposed a sanction barring future pro se filings in that court unless signed by a member in good standing of The Florida Bar.
- Recorded conduct
- The pro se petitioner filed AI-generated petitions and supplements with inaccurate legal arguments and fictitious-authority-like hallucinations after many trial-court AI-generated filings. The court imposed a prospective filing restriction. — outcome: sanctions; 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.
These types of AI-hallucinated arguments are just as egregious as a citation to non-existent law. See Clerk of Court & Comptroller for 13th Judicial Circuit, Hillsborough Cnty. v. Rangel, 427 So. 3d 1069, 1071 (Fla. 2d DCA 2025) (sanctioning counsel for filing a brief that, among other things, “misstated court holdings”). Pro se litigants and attorneys are responsible for their AI-generated filings and may be subject to sanctions for filings that contain fictitious authority or “cite actual cases for inaccurate legal propositions.” Hessert v. Hessert, 51 1 This Court has seen this AI-hallucinated argument often. Seeing it at all is too often. Fla. L. Weekly D520 (Fla. 6th DCA March 20, 2026). Pro se litigants are not held to a lesser standard. Goya v. Hayashida, 418 So. 3d 652, 655 (Fla. 4th DCA 2025). The delay in filing a UCCJEA affidavit does not deprive the trial court of jurisdiction or void the orders entered before the affidavit was filed. Holub v. Holub, 54 So. 3d 585, 588 (Fla.
Authorities cited in the passage: Hillsborough Cnty. v. Rangel, 427 So · Hessert v. Hessert, 51 1 This Court has seen this AI-hallucinated argument often · Pro se litigants are not held to a lesser standard. Goya v. Hayashida, 418 So · Holub v. Holub, 54 So
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