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Incident Tracker / United States (state)

Gouldy v. Chiasson, No. 4D2025-1289 (Fla. 4th DCA)

·Florida Fourth District Court of Appeal·US-STATEPending

Florida's Fourth District Court of Appeal affirmed against a self-represented appellant whose brief relied on a nonexistent case and fabricated quotations from real decisions. Treating phantom authority as sanctionable under the appellate rules, the court issued a separate order requiring her to show cause why she should not be barred from filing further self-represented appeals.

Court
Florida Fourth District Court of Appeal
Date
2026-07-22
Who used the AI
Litigant in person
AI tool
Not identified in the record
Conduct
Self-represented appellant Rose Lannquist Gouldy's brief cited a nonexistent case described by the court as phantom authority, attributed fabricated quotations to real decisions and misrepresented the record.
Outcome
Pending
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

  • Barton v. McGovern, 302 So. 3d 1042 (Fla. 2d DCA 2020) — nonexistent case quoted for an entitlement-to-fees argument
  • Barton v. McGovern, 504 So. 2d 457, 458 (Fla. 1st DCA 1987) — real case that did not contain the quotation Gouldy attributed to Barton
  • Stockman v. Downs, 573 So. 2d 835 (Fla. 1991) — fake quote cited to support a piecemeal-fee-award argument
  • Several fabricated quotes from Florida cases supported the objection to fees for a pro se attorney litigant; the opinion did not enumerate them
  • Initial brief otherwise relied on cases that did not support the propositions cited and misrepresented the record; the opinion did not enumerate each instance

What the court said

“We affirm the appeal in all respects and issue a separate order to show cause as to why Gouldy should not be barred from further pro se filings in this court. Gouldy’s excessively long pro se brief contains frivolous arguments, misrepresentations of the record, a phantom case, and fake quotes from actual cases.”
Florida Fourth District Court of Appeal, p. 1
“Gouldy’s argument relies upon fictitious quotations from Florida case law. She quotes a nonexistent case, Barton v. McGovern, 302 So. 3d 1042 (Fla. 2d DCA 2020), for a proposition that is consistent with her argument.”
Florida Fourth District Court of Appeal, p. 9
“First, it is unclear what Gouldy means by “piecemeal fee awards.” She cites a fake quote from Stockman v. Downs, 573 So. 2d 835 (Fla. 1991), to support this argument.”
Florida Fourth District Court of Appeal, p. 11
“Her initial brief cites a nonexistent case, misrepresents the record, fabricates multiple quotations from actual legal decisions, and otherwise relies upon cases that do not support the propositions for which they are cited.”
Florida Fourth District Court of Appeal, p. 17

Timeline

  1. Trial court began the fee hearing on remand
  2. Fee hearing continued before the trial court
  3. Trial court concluded the fee hearing
  4. Trial court awarded $65,662.23 in appellate fees and costs
  5. Supplemental rehearing motion was denied, rendering the fee order
  6. Fourth District affirmed and issued a separate pro se filing-ban show-cause order

Why this case matters

Gouldy sits between Gleason and the later JMOR and Capital Standard Florida records. It involved a self-represented appellant rather than counsel, so the remedy was an order to show cause about future pro se filings, not a bar referral or fine. The opinion is specific in a way Gleason was not: it names Barton and Stockman examples and ties them to Florida’s growing phantom-authority line. That helps separate ordinary weak pro se briefing from fabricated quotations that can justify a filing ban.

Practice note

Before filing a Florida appeal, a self-represented party should verify each case in the Florida appellate archive or a legal database, then copy the exact passage into a citation log. Do not cite a case found only through an AI tool. If a brief alleges fraud or bad faith, tie it to record pages and remove any claim that the record does not support.

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, “Gouldy v. Chiasson, No. 4D2025-1289 (Fla. 4th DCA)”, safelegalai.com/tracker/gouldy-v-chiasson (accessed 2026-10-07). Data: CC BY 4.0.

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