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Courts on AI / Self-represented litigants using AI

Mathis v. Mathis

Florida Fourth District Court of Appeal · State appellate courts · FL · · No. 4D2025-2986 · opinion

The Florida appellate court notes that a self-represented appellee cited two nonexistent cases. Without imposing sanctions, it disregards the phantom authority and reiterates that attorneys and pro se litigants remain responsible for verifying AI-assisted filings.

Disposition
The court reversed and remanded a child-support order while disregarding phantom authorities in a pro se brief.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

In his answer brief, the husband cites two cases which do not exist. As we recently explained: Such phantom authority cannot assist any litigant and must be expressly disregarded by this court. Attorneys and those, like appellee, who proceed pro se are responsible for the content of their submissions to the court. Those who use artificial intelligence to assist in these submissions must ensure their accuracy.

Authorities cited in the passage: Friend v. Serpa, 425 So. 3d 51 (Fla. 4th DCA 2025)

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