Courts on AI / Fabricated or misquoted citations

Leafwell, Inc. v. The Doc App, Inc.

United States District Court for the Middle District of Florida · Federal district courts · FL · 2026-06-09 · No. 2:25-cv-01132 · order

Fabricated or misquoted citations Competence, fees and billing

On 2026-06-09, in Leafwell, Inc. v. The Doc App, Inc, the Middle District of Florida declined to add new sanctions but warned counsel that the order could support future professional-discipline proceedings. Counsel filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

Disposition: The court denied Leafwell’s motion for party-directed sanctions and imposed no additional sanctions.
Recorded conduct: Attorney Castro’s three motions overstated four cases, discussed a non-existent count, and completely misrepresented five authorities; all cited authority existed in this order. The court denied the requested dismissal/default sanctions and imposed no additional sanctions. — outcome: noted, no consequence; 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.

The remaining issue is not Castro’s use of artificial intelligence (“AI”) but his indolence in failing to review AI’s output.

Authorities cited in the passage: Inc. v. Leafwell

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
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 Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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