Courts on AI / Fabricated or misquoted citations

Richard Paul Smith v. Verra Mobility Corporation

United States District Court for the Middle District of Florida · Federal district courts · FL · 2026-05-01 · No. 8:25-cv-2300-KKM-NHA · order

Fabricated or misquoted citationsChatGPT

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: Counsel was ordered to notify the client and file proof of compliance as the sanction for the ChatGPT-related citation failures.
Recorded conduct: Counsel Jeffrey Sullivan used AI tools including ChatGPT in a motion to dismiss and failed to independently verify several misrepresented or nonexistent authorities. The court imposed client notice and proof-of-compliance sanctions. — 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.

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)'

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: 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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