Incident Tracker / United States (federal)
De Ford v. Koutoulas, No. 6:22-cv-652-PGB-DCI (M.D. Fla.)
·US District Court for the Middle District of Florida, Orlando Division·US-FEDSanctions
In the securities class action over the 'Let's Go Brandon' meme coin, the US District Court for the Middle District of Florida entered default judgment against promoter James Koutoulas as a terminating sanction. Judge Paul Byron cited fabricated legal authority in at least eight filings, defiance of contempt findings and class-notice orders, and vexatious litigation.
- Court
- US District Court for the Middle District of Florida, Orlando Division
- Date
- 2026-08-04
- Who used the AI
- Litigant in person
- AI tool
- ChatGPT (per the defendant's public statements)
- Conduct
- Defendant James Koutoulas, litigating largely without counsel in a securities class action over the LGBCoin meme token, submitted fabricated legal authority across at least eight filings (plaintiffs catalogued more than 40 instances), defied class-notice orders, was held in civil contempt and engaged in vexatious motion practice. The Charlotin database records an earlier warning in December 2025.
- Outcome
- Sanctions
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
What was fabricated or misused
- More than forty instances of fabricated authority across Docs. 403, 463, 470, 477, 490, 535, 545, and 582; the order did not enumerate each citation
What the court said
“Accordingly, the Court enters default judgment against Defendant Koutoulas under its inherent authority and Federal Rules of Civil Procedure 37(b), (c).”
“Defendants Koutoulas and LGBCoin LTD submitted fabricated authority across at least eight separate filings: Docs. 403, 463, 470, 477, 490, 535, 545, and 582.”
“Plaintiffs have catalogued more than forty such instances in a spreadsheet attached to their Motion.”
“Nothing short of the most severe sanctions is appropriate for this egregious conduct.”
Timeline
- Class action was initiated over creation, marketing, and sale of LGBCoin.
- Final amendment to the class action complaint was filed.
- Court approved the class notice plan and ordered Koutoulas to post notice.
- Court granted sanctions, entered default judgment, and allowed fee petition.
Why this case matters
De Ford shows AI-fabricated authority operating as one part of a broader bad-faith litigation record. Unlike Mata v Avianca or Barteca, the sanction was not a stand-alone fine for a lawyer’s brief. It was default judgment against an attorney-litigant after fabricated authority, class-notice interference, discovery violations, and repeated rejected arguments. The record is a contrast to In re Booker, where a self-represented appellant received only an admonishment. Here, pro se status did not reduce the consequence because the party was also a licensed attorney and the misconduct spanned years.
Practice note
A self-represented party, especially one admitted to practice, must verify AI-suggested authority in the same way as counsel of record. Open the full case, confirm the proposition, and keep the source. Separately, do not alter court-approved class notices or repeat arguments after an order rejects them; those acts can turn citation defects into terminating sanctions.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “De Ford v. Koutoulas, No. 6:22-cv-652-PGB-DCI (M.D. Fla.)”, safelegalai.com/tracker/de-ford-v-koutoulas (accessed 2026-10-07). Data: CC BY 4.0.