Incident Tracker / United States (state)
Kid International, LLC v. City National Bank of Florida, No. 4D2025-2599 (Fla. 4th DCA 2026)
·District Court of Appeal of Florida, Fourth District·US-STATESanctions
In Florida's Fourth District Court of Appeal, counsel for Kid International filed an AI-assisted brief citing a hallucinated case seven times and fabricated quotations from real authorities. The court affirmed on the merits, granted the opposing party's sanctions motion, and ordered the appellants and their counsel jointly and severally liable for the appellees' reasonable appellate attorney's fees.
- Court
- District Court of Appeal of Florida, Fourth District
- Date
- 2026-10-07
- Who used the AI
- Lawyer
- AI tool
- generative AI (unspecified)
- Conduct
- The appellants' initial brief, drafted with generative AI and client-supplied research, relied on a hallucinated case cited seven times with a fictional quotation, cited a real case with a wrong citation, court and year, and attributed quotations to real authorities that did not appear in them. The pro se complaint below had earlier cited thirty-two cases, fifteen of them non-existent.
- Outcome
- Sanctions
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-10-07
What was fabricated or misused
- Ogilvie v. Sebring Airport Authority, 841 So. 2d 529 (Fla. 2d DCA 2003) — hallucinated case cited seven times, with a fictional quotation
- Mansolillo v. Parties by Lynn, Inc., 173 So. 3d 112 (Fla. 4th DCA 2015) — real case cited with a wrong citation, court and year, not supporting the proposition, and with a quotation not in the opinion
- Seaboard Air Line Railroad Co. v. Holt, 92 So. 2d 169 (Fla. 1956) — quotation attributed to the case that does not appear in the opinion
- Silvestrone v. Edell, 721 So. 2d 1173 (Fla. 1998) — relied on for several propositions not accurately excerpted from the opinion
- Pro se complaint below cited thirty-two cases: fifteen non-existent, two accurate citations with misstated holdings, fourteen inaccurately cited with misstated holdings, one correct
What the court said
“Because of these fabricated references to non-existent cases and inaccurately cited legal authorities, we issued an order to the plaintiffs to show cause why we should not strike the initial brief or impose other sanctions.”
“counsel's law firm incorporated generative artificial-intelligence ("AI") technology as one component of the legal research and drafting process.”
“we grant the defendants' motion for sanctions and award defendants their reasonable attorney's fees incurred in litigating this appeal. On remand, the circuit court shall set the amount of the reasonable attorney's fees to be awarded for this appellate case.”
“The plaintiffs and their counsel shall be jointly and severally liable for the payment of this award.”
Timeline
- Court affirmed on the merits, granted the sanctions motion and remanded for the circuit court to fix the fee amount; appellants and counsel held jointly and severally liable.
Why this case matters
The Fourth District extended appellate sanctions for hallucinated authorities beyond a court's own Rule 9.410(a) power to a party's fee motion under Rule 9.410(b), so an opposing party can recover the cost of chasing fake cases. The order also makes counsel, not only the client, liable, and treats an AI-assisted brief that counsel failed to verify as sanctionable even after an amended brief that still did not fix every citation.
Practice note
Counsel who use generative AI or client-supplied research in a brief must independently locate and check every case against an authoritative source before filing. Removing or amending a brief after the court flags fake citations does not avoid sanctions if the verification failed in the first place, and in the Fourth District the opposing party can recover its fees under Rule 9.410(b).
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, “Kid International, LLC v. City National Bank of Florida, No. 4D2025-2599 (Fla. 4th DCA 2026)”, safelegalai.com/tracker/kid-international-v-city-national-bank (accessed 2026-10-07). Data: CC BY 4.0.