Courts on AI / Fabricated or misquoted citations

Kings Roofing NWFL, LLC v. Fusion Works Construction, LLC

Sixth District Court of Appeal of Florida · State appellate courts · FL · 2026-05-22 · No. Case No. 6D2025-1251 · order

Fabricated or misquoted citations Competence, fees and billing

On 2026-05-22, in Kings Roofing v. Fusion Works, District Court of Appeal of Florida, Sixth District ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed an initial brief using quotations that did not appear in the cited source, several nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Disposition: The court dismissed the appeal by stipulation but retained jurisdiction and ordered counsel to show cause why sanctions and Florida Bar referral should not issue.
Recorded conduct: Attorney Steven McCommon’s initial brief cited several cases, some appearing fabricated, and some quotations unsupported by real authorities. The court ordered him to show cause about sanctions and possible Florida Bar referral. — outcome: pending; 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.

McCommon, Esquire, who, in his Initial Brief, has provided this Court with citations to several cases, some of which appear to be fabricated. The Initial Brief looks as if it was drafted with the assistance of generative artificial intelligence without Mr. McCommon having put sufficient safeguards in place to ensure the existence or accuracy of the cases cited therein. This is unfortunately not the first time our Court has encountered a filing with citations to cases that do not exist or to cases that are cited for inaccurate legal propositions. See, e.g., Rodriguez v. Rodriguez, No. 6D2025-3086, 2026 WL 969721 (Fla. 6th DCA Apr. 10, 2026). As we did in Rodriguez, we hereby direct Mr. McCommon to provide copies of each and every case cited in the Initial Brief that actually exists, with highlighted quotations or language that support the assertions made in the Initial Brief. These cases shall be filed with this Court within ten days of the issuance of this Order. Additionally, Mr.

Authorities cited in the passage: Rodriguez v. Rodriguez, No. 6D2025-3086, 2026 WL 969721 (Fla. 6th DCA Apr. 10, 2026)

Court document: storage.courtlistener.com
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
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. Official copy located 2026-09-08 at storage.courtlistener.com; quoted passage confirmed. Re-coded from the document 2026-09-08 (independent second read).

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