Courts on AI / Fabricated or misquoted citations
Richard Paul Smith v. Verra Mobility Corporation et al.
United States District Court for the Middle District of Florida · Federal district courts · FL · · 2026 WL 1197241 · No. 8:25-cv-2300-KKM-NHA · order
The Middle District of Florida on 2026-05-01 ordered counsel to notify the client about mis-cited and nonexistent cases and required a client-signed certification in Richard Paul Smith v. Verra Mobility Corporation et al. Counsel filed a motion with three fabricated case citations and one mischaracterized case citation, including Morgulis v. BusPatrol Am.
- Disposition
- The court ordered counsel to notify the client about mis-cited and nonexistent cases and required a client-signed certification.
- Recorded conduct
- Counsel filed a motion with three fabricated case citations and one mischaracterized case citation, including Morgulis v. BusPatrol Am and Gonzalez v. City of Coral Gables after using ChatGPT. — outcome: other; 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.
48) at 32–33, 41. Sullivan timely responded and “does not dispute the errors identified in the Order. ” Resp. (Doc. 50) at 2. Sullivan acknowledges that he used artificial intelligence tools, including ChatGPT, to research and draft the School Board's motion to dismiss. See id. at 2–3. He admits that he did not “complete an independent verification of each citation before filing and did not realize at the time that the cited authorities were inaccurate or unsupported. ” Id. at 3. Sullivan accepts full responsibility for the errors and does not attribute them to the School Board or anyone else. Id.
Authorities cited in the passage: School Board relied on 'Morgulis v. BusPatrol Am., LLC, 2020 WL 1923164, at *8–9 (E.D.N.Y. Apr. 21, 2020)' as authority · School Board cited a non-existent decision 'Gonzalez v. City of Coral Gables, 2018 WL 2392077 (S.D. Fla. May 25, 2018)' · School Board cited a non-existent decision 'Abreu v. City of Miami Beach, 2021 WL 3625049 (S.D. Fla. Aug. 16, 2021)'
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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