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 · · No. 2:25-cv-01132-JES-KRH · opinion
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 declined to add new sanctions but warned counsel that the order could support future professional-discipline proceedings.
- Recorded conduct
- 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. — outcome: sanctions; 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.
Across these motions, the Court finds Castro: (1) overstated the breadth of four cases; (2) discussed a non-existent count; (3) completely misrepresented five cited authorities; and, most troubling of all, (4) failed to take responsibility for clearly failing to review his motions. Leafwell requests the Court dismiss with prejudice My Florida Green’s related claims against Leafwell and/or grant a default judgment against My Florida Green in this case. (Doc. #40, p. 26.) The Court, however, finds these proposed sanctions excessive. Castro already has ongoing obligations from the previous sanctions order issued by District Court Judge Sherri Polster Chappell, under which Castro is obligated to pay attorney’s fees, must attach a copy of Judge Chappell’s order to any case he files or removes to the Middle District of Florida, and was referred to the Florida Bar for appropriate discipline. See The Doc App, Inc. v. Leafwell, Inc., No. 2:25-cv-838-SPC-NPM, 2025 WL 3288251 (M.D. Fla. Nov. 26, 2025).
Authorities cited in the passage: Inc. v. Leafwell