Courts on AI / Fabricated or misquoted citations

Rose v. Arts Bonita, Inc.

United States District Court for the Middle District of Florida · Federal district courts · FL · 2026-08-12 · 2026 WL 2329753 · No. 2:26-cv-484-KCD-KRH · order

Fabricated or misquoted citations Self-represented litigants using AI

The Middle District of Florida partly grants Arts Bonita’s motion about generative AI use. The court finds Julia Rose cited a nonexistent Prousalis case, later withdrew it as incorrect or unverifiable, declines sanctions for a single hallucinated citation, and warns future inaccurate authority may be sanctioned.

Disposition: The court partly granted an AI-use motion by warning Rose; it declined to impose a broader AI-use order.
Recorded conduct: Self-represented plaintiff cited nonexistent Prousalis v. Bert's Bikes & Fitness, then withdrew it as incorrect or unverifiable. — outcome: warning; actor: litigant in person
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.

In her response to Arts Bonita's motion to dismiss, Rose cited Prousalis v. Bert's Bikes & Fitness, No. 8:18-cv-1234, 2019 WL 13202785 (M.D. Fla. 2019). That case does not exist. Once Arts Bonita caught the error, it asked Rose to join an agreed order on generative AI use. The City signed on, but Rose refused, telling counsel that as a pro se litigant she did not want to limit her own access to research and accessibility tools and promised to keep reviewing her filings for accuracy herself. ... Rose eventually filed a notice withdrawing the citation, admitting only that the citation was “incorrect or unverifiable.” ... Rose's conduct falls near the bottom of that range—i.e., a single hallucinated citation. Even so, a fabricated citation is never harmless since it forces the opposing party and the Court to “waste time and money in exposing the deception.” ... A sanction is not yet warranted, but the record supports an admonishment. This is the only warning Rose will receive for her infraction.

Authorities cited in the passage: Prousalis v. Bert's Bikes & Fitness, 2019 WL 13202785 (M.D. Fla. 2019) · Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enterprises, LLC, 2025 WL 1440351 (S.D. Fla. May 20, 2025) · Kendrick v. Secretary, Florida Department of Corrections, 2022 WL 2388425 (11th Cir. July 1, 2022) · O'Brien v. Flick, 2025 WL 242924 (S.D. Fla. Jan. 10, 2025) · Mata v. Avianca, Inc., 678 F. Supp. 3d 433 (S.D.N.Y. 2023) · Fed. R. Civ. P. 11

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public mirror; official copy pendingprovisional
Found via: charlotin-cc0
Notes: Official source not obtained after CourtListener throttling; read the court-authored text from the Charlotin mirror. The mirror text appears to include Westlaw formatting.

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