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Incident Tracker / United States (state)

Gleason v. Marcus, No. 2D2024-2688 (Fla. 2d DCA)

·Florida Second District Court of Appeal·US-STATEWarning

Florida's Second District Court of Appeal affirmed the dismissal of Christopher Gleason's pro se election complaint and admonished him for apparent AI use: his briefs cited numerous non-existent cases and quoted authorities for propositions found nowhere in them. The court warned that future filings of that nature would not receive favorable treatment and reminded all litigants to verify their filings.

Court
Florida Second District Court of Appeal
Date
2026-05-13
Who used the AI
Not recorded
AI tool
Not identified in the record
Conduct
Self-represented appellant Christopher Gleason, challenging the dismissal of his election-related complaint against the Pinellas County Supervisor of Elections, filed appellate briefs that cited numerous cases that do not exist and frequently quoted case law for propositions appearing nowhere in the authorities cited — which the court attributed to his apparent use of artificial intelligence to prepare the briefs.
Outcome
Warning
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

  • Numerous cases cited in the appellant’s briefs did not exist; the court did not enumerate them
  • Case-law quotations in the appellant’s briefs were used for propositions that appeared nowhere in the cited cases; the court did not enumerate them

What the court said

“But we are compelled to comment on Mr. Gleason's apparent use of artificial intelligence to prepare the briefs he filed with this court.”
Florida Second District Court of Appeal, p. 2
“His briefs cite numerous cases that do not exist, and they frequently quote case law for propositions that appear nowhere in the cases cited.”
Florida Second District Court of Appeal, p. 2
“"This technology is very good at sounding right, but less adept at being right," and "blind reliance" on it is unwise, unacceptable, and sanctionable.”
Florida Second District Court of Appeal, p. 2
“We notify Mr. Gleason that future filings of this nature will not receive favorable treatment, and we remind all litigants—both pro se and represented—that they must ensure the accuracy of their filings or risk the consequences.”
Florida Second District Court of Appeal, p. 2

Timeline

  1. Notice of appeal recorded in the Pinellas County docket.
  2. DCA ordered appellant to serve the initial brief within 10 days or face dismissal.
  3. DCA said the appeal would proceed on the initial, answer and reply briefs.
  4. Second District affirmed dismissal and warned about apparent AI use.
  5. Mandate issued per curiam affirmed.

Why this case matters

Gleason is a pro se appellate warning rather than a lawyer-discipline order. That distinguishes it from Park v Kim and Wadsworth v Walmart, where Rule 11 or bar duties drove sanctions against counsel. The Florida court did not list the false authorities or impose a fine, but it placed all litigants on notice that briefs using non-existent cases or unsupported quotations may draw sanctions. It also ties the warning to a growing Florida line, including Gutierrez and Gouveia, aimed at self-represented and represented filers alike.

Practice note

A self-represented appellant should verify citations the same way a lawyer would: find the case in the official appellate archive or a trusted legal database, read the passage, and cite only propositions that appear there. Opposing parties should point out nonexistent cases or inaccurate propositions in a response or motion rather than leaving the court to find them.

Primary sources for this incident

Related regulation records for this incident

Similar incidents on the record

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  • Noble v. WMC Mortgage Corp., 2026 IL App (1st) 251168-U2026-08-28 · Appellate Court of Illinois, First District · WarningIn Illinois, self-represented litigant Sanja Noble's mortgage appeal brief included a hallucinated citation to Ferguson v. Georges for the standard of review. The Appellate Court found the citation actually led to Peopl…
  • Kiser v. DeSimone Auto Group, No. 2428 EDA 2025 (Pa. Super. Ct.)2026-08-27 · Superior Court of Pennsylvania · WarningIn Pennsylvania, counsel for Paige and Ty Kiser cited a non-existent Superior Court decision, Com. v. Reid, for an appellate issue in a consumer dispute. The Superior Court called the authority counterfeit, suggested ch…
  • Salloum v. Department of Transportation, No. 25CA1748 (Colo. App.)2026-08-27 · Colorado Court of Appeals · WarningIn Colorado, self-represented appellant Ayman Salloum filed an opening brief citing three authorities the Court of Appeals could not verify, including one dated in the future. Applying Al-Hamim's warning on generative-A…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Gleason v. Marcus, No. 2D2024-2688 (Fla. 2d DCA)”, safelegalai.com/tracker/gleason-v-marcus (accessed 2026-09-16). Data: CC BY 4.0.

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