Florida

Jorge A. Zea v. National Association of REALTORS

False Quotes: Case Law | Response contains fabricated quotations and paraphrases attributed to real cases across multiple pages; Court found quotations and legal concepts were fake and unreliable. || Misrepresented: Doctrinal Work | Advanced an AI-invented doctrinal claim that an association's 'concerted action' removes the need to plead a conspiracy or agreement; Court rejected this as invented law. || Misrepresented: Case Law | Included U.S. Anchor Manufacturing 'incorrectly' as support; Court noted the plaintiff acknowledged the inclusion was erroneous and that other cited cases were misapplied.

Samantha Roussell v. The Bank of New York Mellon

Fabricated: Case Law | Appellant's brief cited thirteen cases that do not exist; the court expressly disregarded these fabricated cases. || Misrepresented: Case Law | Appellant cited nine existing cases but attributed propositions to them that they do not support; the court noted these misrepresentations.

Juandel Pena and Martina Ruiz v. Wells Fargo Bank, N.A.

Fabricated: Case Law | Plaintiffs cited Holden v. Holiday Inn Club Vacations, Inc., 98 F.4th 1359 with a pinpoint to page 1371; the court noted Holden ends at page 1369 and that the cited page does not exist, suggesting an AI-generated or otherwise fabricated citation.

Johnson v. Florida Department of Juvenile Justice et al

Fabricated: Case Law | Watson v. Amedisys Holding, LLC, 298 F. App'x 395, 396 (5th Cir. 2008) || Fabricated: Case Law | Martin v. Dep't of Corrections, 682 So. 2d 331, 333 (Fla. 5th DCA 1996)

Lindsey Newell v. The Law Offices of Travis R. Walker, et al.

Fabricated: Case Law | The defendants' original response contained an apparent AI-generated hallucination (incorrect/crafted case citation); the Court notified defendants and they withdrew the response.

Mitchell Taylor Button & Dusty Button v. Sigrid McCawley

Fabricated: Case Law | Plaintiffs cited In re: Marriage of Smith, 195 Cal. App. 4th 1007, 1018 (2011), which the court identified as a non-existent authority as presented. || False Quotes: Case Law | Plaintiffs attributed the quotation "Dismissal based on a legal defense does not equate to frivolity." to Parekh; court found Parekh contains no such language. || False Quotes: Case Law | Plaintiffs attributed a quotation about use of confidential information to In re Shell Oil Refinery; court found the quoted material is not in that case. || Fabricated: Case Law | Plaintiffs cited Lopez v. Bank of Am., N.A., No. 14-cv-2524, 2016 WL 4131149 (N.D. Cal. Aug. 3, 2016), which the court found does not exist as cited. || Fabricated: Case Law | Plaintiffs cited Harris v. City of Auburn, 2018 WL 3329858 (M.D. Ala. July 6, 2018), which the court determined was a mis-citation (the cited decision did not exist as presented). || Fabricated: Case Law | Plaintiffs cited Avery v. Ward, 2014 WL 4748452, at *3 (S.D. Ala. Sept. 23, 2014), which the court found does not exist as cited. || False Quotes: Case Law | Plaintiffs quoted language attributed to Schwartz v. Millon Air, Inc., 341 F.3d 1220, 1225 (11th Cir. 2003) that does not appear in that opinion; court found the quotation fabricated/misattributed. || Misrepresented: Exhibits & Submissions | Plaintiffs claimed the magistrate's R&R contained language calling them 'serial litigants' and accusing them of filing to 'harass' and being 'retaliatory'; the court found those characterizations do not appear in the R&R.

Nelson Henry v. Joseph Iannone and James Deacetis

False Quotes: Case Law | Plaintiff quoted a passage attributed to Sims v. Metro. Dade Cnty. that the court found does not appear in that opinion and was used to argue summary-judgment standards regarding video evidence. || False Quotes: Case Law | Plaintiff relied on a purported quotation from Shaw v. City of Selma that the court characterized as among the plaintiff's seemingly hallucinated quotations from case law.

Farag v. Persante et al

Fabricated: Case Law | Plaintiff cited 'Holt v. Crown Builders, Inc., 627 So.2d 1221 (Fla. 2d DCA 1993)'; court found this authority does not exist. || Fabricated: Case Law | Plaintiff cited 'Bennett v. Bivins, 685 Case 8:25-cv-03056-SDM-AEP,' which the court found to be nonexistent or erroneous. || Misrepresented: Legal Norm | Plaintiff misquoted Section 733.903, Florida Statutes; the quoted language does not appear in the statute and the court corrected the actual statutory text. || Misrepresented: Exhibits & Submissions | Plaintiff claimed Exhibit 1 was an entry of clerk's default, but the court found Exhibit 1 was not an entry of default. || Misrepresented: Exhibits & Submissions | Plaintiff asserted Exhibit 3 was a 'formal Certificate of Default'; court found Exhibit 3 was the plaintiff's motion for default, not an entered order. || Misrepresented: Exhibits & Submissions | Plaintiff alleged the lawyer appeared 'without any lawful authority or court approval,' but Exhibit 5 was the lawyer's notice of appearance filed in compliance with rules.

Ralph J. Massetti, Jr. v. Greenspring Capital Management, LLC, et al.

Fabricated: Case Law | Plaintiff's Second Amended Complaint cited legal authorities the Court was unable to locate, suggesting the authorities do not exist or were miscited; Greenspring identified these nonexistent citations in its motion.

Peter J. Allsot, as next friend of B.P.L.A. v. Naseem Latif

Fabricated: Case Law | Plaintiff cited M.S. ex rel. S.S. v. Wermers, 74 F.3d 857 (8th Cir. 1996); the Court determined the citation appears incorrect or that the case does not exist.

Hodges v. Meridian Waste & Rieske v. AFS

Fabricated: Case Law | AI-generated fabricated case citations were included in briefs filed in Hodges v. Meridian Waste (3:25-cv-62); court found citations were fake, counsel admitted use of AI, and court imposed sanctions while accepting counsel's contrition. || Fabricated: Case Law | AI-generated fabricated case citations were included in briefs filed in Rieske v. Accounting Fulfillment Services (5:25-cv-45); court found citations were fake, counsel admitted use of AI, and court imposed sanctions while accepting counsel's contrition.

Hayes v. Chipotle Mexican Grill

Fabricated: Case Law | Court found the citation to 'Capistrano v. Fin. Indus. Regulatory Auth., Inc., 2015 WL 1647091, at *3 (M.D. Fla. Apr. 14, 2015)' does not exist and flagged it as an inaccurate authority. || Fabricated: Case Law | Court found the citation to 'Dept. of Fair Emp't & Hous. v. Law Sch. Admission Council, Inc., 2014 WL 4269110, at *8 (N.D. Cal. Aug. 28, 2014)' does not exist and flagged it as an inaccurate authority. || Fabricated: Case Law | Court found the citation to 'Perez v. Zazo, 498 So. 2d 463, 465 (Fla. 3d DCA 1986)' does not exist as cited and flagged it as an inaccurate authority. || Fabricated: Case Law | Court found the citation to 'Byrd v. Shumann, 2013 WL 12091938, at *2 (S.D. Fla. Jan. 28, 2013)' does not exist and flagged it as an inaccurate authority.

Ayatollah Hylton v. Chivone Janee Hylton, et al.

Fabricated: Case Law | Plaintiff cited and quoted a non-existent order: attributed the language "A last-minute email or single communication is insufficient to satisfy Local Rule 7.1(a)(3). Motions filed without good-faith conferral may be denied or stricken." to "Wachovia Bank v. Tien, No. 05-60821, 2008 WL 11333017 (S.D. Fla. Feb. 12, 2008)"; the court found no case at that Westlaw citation and that the citation/quote were inaccurate.

Florida SB 482

Florida legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Florida HB 1395

Florida legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Friend v. Serpa

Fabricated: Case Law | Appellee included multiple non-existent case citations (phantom authority); court found them fabricated and instructed they be disregarded.

Russell v. Mells

Fabricated: Case Law | Appellee's brief cited a non-existent authority, "Cade v. Roberts, 403 So. 2d 516 (Fla. 5th DCA 1981)," as support for a motion-to-dismiss principle; court's research found no such reported case and that the cited page belonged to Girardeau v. State, which is unrelated. || False Quotes: Case Law | Two Southern Reporter cases cited in the brief were misquoted — the brief attributed quoted text to one case that actually appeared in another opinion; court found the quotations were misplaced and inaccurate.

Jacob Barry Allston v. Ron DeSantis, et al.

Fabricated: Case Law | Plaintiff cited a purported Eleventh Circuit case 'United States v. Roses, 39 F.4th 113 (11th Cir. 2022)' which the Court found does not appear to be a real case. || False Quotes: Case Law | Plaintiff attributed a quotation to Jackson v. Bank of Am. that the Court and opposing counsel showed does not appear in that decision. || False Quotes: Case Law | Plaintiff attributed a quote to Varnes v. Local 91 (674 F.2d 1365) that the Court found is not present in that case.

Ali Taj Bey v. Mark Glass

Fabricated: Case Law | Plaintiff's complaint cites 'Ford v. Browning, 568 F.3d 1175 (11th Cir. 2009)'; the Court could not find this Eleventh Circuit case and described the citation as a likely AI-generated hallucination.

The Doc App, Inc. d/b/a My Florida Green v. Leafwell, Inc.

Fabricated: Case Law | Motion cited Henson v. Allison Transmission with reporter/citation No. 6:16-cv-1223-Orl-41DCI, 2017 WL 59085 (M.D. Fla. Jan. 5, 2017), which the Court confirmed does not exist; counsel later said he intended a different Henson (2008 WL 239153), but that case does not support the propositions cited. || Misrepresented: Case Law | Motion cited State Farm Mut. Auto. Ins. Co. v. Pressley as 727 So. 2d 1019, 1020 (Fla. 3d DCA 1999) (yielded nothing in Westlaw); counsel later pointed to 28 So. 3d 105 (Fla. 1st DCA 2010), but that decision does not contain the quoted phrase or discuss the statute counsel attributed to it. || False Quotes: Case Law | At least two quotations in the Motion were presented as direct quotes but the cited cases do not contain the quoted language (counsel claimed an earlier draft/paraphrase error).

David Morris Clayman v. Scott Bessant

Fabricated: Case Law | Plaintiff cited 'United States v. Bovio, 708 F. Supp. 2d 579 (E.D.N.Y. 2010)'; the Court found the case does not exist and concluded it was AI-generated; plaintiff conceded and apologized.

Alexey Dubinin v. Varsenik Papazian

Fabricated: Case Law | Plaintiff's Response cited a decision from this Court that does not exist; the Court's independent review confirmed non-existence. || False Quotes: Case Law | Response included quotations attributed to Eleventh Circuit opinions that do not appear in those opinions; Court identified multiple such misquotes. || Fabricated: Case Law | Court's Order to Show Cause listed at least ten instances across the Complaint and Response citing non-existent cases and quotes (AI-hallucinated authorities).

Arch Insurance Company v. A3 Development, LLC

Fabricated: Case Law | Court observed that Solis v. Zenith Cap., LLC, No. 19-80730-CIV, 2019 WL 7376782 (S.D. Fla. Sept. 26, 2019), cited by defendants, appears not to exist; cited in defendants' response to support their position. || Fabricated: Case Law | Court noted another citation in defendants' response (PGA Nat'l Resort, LLC v. Liberty Mut. Fire Ins. Co., 2016 WL 8716673, at *3 (S.D. Fla. Oct. 24, 2016)) appears to be non-existent or invalid.

Charles C. Force v. Capital One, N.A., et al.

Misrepresented: Case Law | Plaintiff cited Graves v. Smith's Transfer Corp., 736 F.2d 819, 820 (1st Cir. 1984) for a proposition the case does not hold; the Court found the case does not discuss the asserted point. || Outdated Advice: Overturned Case Law | Plaintiff relied on Scheuer v. Rhodes, 416 U.S. 232, 236 (1974) to state the old 'no set of facts' pleading standard, but the Court noted that the standard was retired by Bell Atlantic v. Twombly (2007). || Fabricated: Case Law | Plaintiff cited Phillips v. Phillips, 685 So. 2d 85 (Fla. 1st DCA 1996), but the Southern Second citation corresponds to Lowe Inv. Corp. v. Clemente, 685 So. 2d 84; the named Phillips opinion did not exist at that citation. || Fabricated: Case Law | Plaintiff cited Brydger v. Brydger, 910 So. 2d 381 (Fla. 4th DCA 2005), but the Southern Second citation corresponds to Whitley v. Royal Trails Prop. Owners' Ass'n, Inc., 910 So. 2d 381; the named Brydger citation was incorrect. || False Quotes: Case Law | Plaintiff attributed a specific quoted phrase to U.S. v. Int'l Brotherhood of Teamsters, 266 F.3d 45 (2d Cir. 2001), but the Court found no such quote in that opinion. || Fabricated: Case Law | Plaintiff cited a non-existent case captioned Ashley v. Bank of Am., 538 F. App'x 874; the cited Federal Appendix citation did not correspond to that caption. || Misrepresented: Case Law | Plaintiff cited an advisory opinion captioned In re Advisory Opinion to the Governor re: Dual Representation of State Officers, 630 So. 2d 1055 (Fla. 1994) and attributed holdings about the Attorney General that the opinion does not contain; the citation and summary were misleading.

USA v. Brewer

Outdated Advice: Overturned Case Law | United States v. Mmahat was cited for broad discoverability of probation files but the decision was abrogated and unrelated to revocation proceedings; subsequent history not cited. || False Quotes: Case Law | Quoted language attributed to United States v. Frazier does not appear in that decision and the case is unrelated to supervised release. || False Quotes: Case Law | Brady quotation omitted the words "upon request," altering its meaning. || False Quotes: Case Law | Quoted language attributed to United States v. Hasting does not appear in the opinion (similar language appears only in a concurrence). || Misrepresented: Case Law | United States v. Bundy was cited for authority to order discovery beyond Rule 32.1, but the cited opinion does not address Rule 32.1, probation, or supervised release. || Misrepresented: Case Law | United States v. Price cited for a proposition about phone records, but the decision does not concern telephone records. || Fabricated: Case Law | United States v. Noel (708 F.3d 245, 254 (1st Cir. 2013)) is entirely fabricated and does not exist as cited. || False Quotes: Case Law | Quoted sentence attributed to United States v. Safavian does not appear in that opinion. || Misrepresented: Case Law | United States v. Siddiqui does not support the proposition that computer audit logs are discoverable for timing/access; the citation was misused. || Fabricated: Case Law | United States v. Hernandez (183 F. Supp. 3d 468, 480 (S.D.N.Y. 2016)) is entirely fabricated according to the court.

Multiphone Latin America v. Millicom International Cellular

Misrepresented: Case Law | Response cites at least four existing cases for propositions those opinions do not discuss (e.g., citing Morrison v. Nissan Motor Co., 601 F.2d 139 for an unrelated point); Court identified misapplication of authority. || False Quotes: Case Law | Proposed Sur-Reply and Response attribute quoted language to Cohen v. Cooper (20 So. 3d 453) that does not appear in that opinion; Court identified the misquote. || False Quotes: Case Law | Counsel presented quotes drawn from Westlaw Keynotes as if they were verbatim text from opinions (examples include Rollins and Stewart), a misrepresentation the Court noted. || Fabricated: Case Law | Response cites 'Metropolitan Dade County v. Dyer, 315 So. 2d 442, 444 (Fla. 3d DCA 1975)', which the Court found appears not to exist. || Fabricated: Case Law | Response cites 'QBE Ins. Corp. v. Dome Constr. Corp., 10 So. 3d 676, 678 (Fla. 4th DCA 2009)', another authority the Court determined appears to be nonexistent.

Monster Energy Company v. John H. Owoc

Fabricated: Case Law | Defendant's motion and reply contained eleven fabricated case-law citations generated by AI; the Court read them into the record and found a Rule 11(b)(2) violation.

Robbins v. Martin Law Firm, P.L.

Fabricated: Case Law | Plaintiff cited a non-existent M.D. Fla. decision as Baker v. BDO Seidman, LLP; court notes plaintiff conceded the citation was incorrect and the real case was a non-binding N.D. Cal. decision not involving bankruptcy. || False Quotes: Case Law | Plaintiff attributed a sentence about remand promoting judicial economy and discouraging forum shopping to Republic Reader’s; the court found the quotation does not exist in the opinion. || False Quotes: Case Law | Plaintiff quoted Eastus as requiring courts to weigh in favor of remand in non-core state law proceedings; the court found the quotation does not exist and noted Eastus did not involve bankruptcy. || Misrepresented: Case Law | Plaintiff cited Kircher for the burden of establishing federal jurisdiction on the removing party; the court explained Kircher addressed appellate review of remand orders and footnote 12 was unrelated. || Misrepresented: Case Law | Plaintiff asserted Hirsch reaffirmed that malpractice and fiduciary duty claims are generally non-core and belong in state court; the court noted plaintiff conceded this was inaccurate, with only state-law application being similar.

Nunez v. American Airlines, Inc.

Fabricated: Case Law | Plaintiff cited a non-existent case 'Doe v. Major Airline (2020)'; court confirmed the case does not exist and included it among fabricated authorities that warrant sanction. || Fabricated: Case Law | Plaintiff cited a non-existent case 'Greene v. American Airlines, No. 18-CV-11459, 2019 WL 1949830 (S.D.N.Y. May 1, 2019)'; court confirmed the case does not exist and treated the citation as fabricated authority warranting sanctions.

ByoPlanet International v. Johansson and Gilstrap

False Quotes: Case Law | Fabricated Scalia quote attributed to Liteky; court verified the quote does not appear in the opinion. || Fabricated: Case Law | Complaint cited a non-existent case; court noted the reporter citation corresponds to Roberts v. State, not Merrill Lynch v. Hagerty. || Fabricated: Case Law | Response cited a non-existent S.D. Fla. case; citation actually points to a Louisiana case. || False Quotes: Case Law | Quoted Hood for a Rule 11 proposition not found in the case; court confirmed the quote does not appear and the case does not discuss 'clerical errors' or 'bad faith.' || Fabricated: Case Law | Appeal brief cited a non-existent Castillo decision. || Misrepresented: Case Law | Misstated Castillo as holding that knowingly false testimony by an agent/expert warranted reopening judgments; court noted real Castillo decisions do not support this. || Fabricated: Case Law | Appeal brief cited a non-existent Chowdhury decision. || Fabricated: Case Law | Appeal brief cited a non-existent Nabulsi decision. || Fabricated: Case Law | Appeal brief cited a non-existent Olson decision. || Fabricated: Case Law | Appeal brief cited a non-existent Perkins decision. || Fabricated: Case Law | Response cited a non-existent Fourth DCA decision; opposing party flagged the fabrication. || Fabricated: Case Law | Response cited a non-existent Kaplan decision. || False Quotes: Case Law | Motion cited Ehlers for a Rule 60(b) 'liberally construed to do substantial justice' quote that does not appear in the case. || False Quotes: Case Law | Show-cause response attributed a bad-faith requirement quote to Purchasing Power that does not appear in the opinion. || False Quotes: Case Law | Show-cause response quoted Carroll as declining sanctions for incorrect citations absent intent to mislead; the quoted language does not appear.

Crespo v. Tesla, Inc.

Fabricated: Case Law | Plaintiff cited Perez v. Miami-Dade Cnty., 297 F.R.D. 620, 625 (S.D. Fla. 2013) in DEs 61, 63, 78, 79, 80; the Court found this case appears nonexistent. || Fabricated: Case Law | Plaintiff cited Jacobs v. Atrium Med. Corp., 2020 WL 5803503, at *2-3 (S.D. Fla. Sept. 29, 2020) in DEs 61, 63, 78, 79, 80; the Court found this case appears nonexistent. || False Quotes: Case Law | Plaintiff quoted Universal City Dev. Partners, Ltd. v. Ride & Show, 230 F.R.D. 688, 695 (M.D. Fla. 2005) as saying “is tantamount to no objection at all.” (DE 78 at 2); the Court found no such quote exists in that case.

Versant Funding v. Teras Breakbulk Ocean Navigation Enterprises

Fabricated: Case Law | Defense cited a non-existent case to argue privilege assignments must be clear and unmistakable; Plaintiff could not find it on Westlaw/Lexis, the Court also could not locate it, and defense later withdrew and admitted AI use.

USA v. Burke

False Quotes: Case Law | Attributed a quote to Ruiz that does not exist and used it for an unsupported proposition. || Misrepresented: Case Law | Claimed Ruiz supports the rule that statutes cannot require defendants to prove exculpatory facts, which the case does not support. || False Quotes: Case Law | Falsely quoted Gray as saying it is impermissible to require a defendant to prove a negative essential to innocence. || Misrepresented: Case Law | Cited Green for the proposition that the government must disprove statutory exceptions, which the case does not support. || Misrepresented: Doctrinal Work | Relied on a House Judiciary Report that concerns the Flammable Fabrics Act Amendments, not the relevant legislation. || False Quotes: Case Law | Falsely quoted Tsurkan as stating the Wiretap Act's primary objective is protecting telephone conversations from interception. || Misrepresented: Case Law | Miscited Tsurkan; provided a reporter citation that corresponds to a different case and not the quoted material. || False Quotes: Case Law | Attributed to Hasson a constitutional avoidance quote not stated there. || False Quotes: Case Law | Attributed to Doe v. Miami-Dade County a quote about constitutional avoidance being strongest when protecting fundamental rights, which is not stated there. || False Quotes: Case Law | Falsely quoted McQueen as stating the government must prove each element beyond a reasonable doubt. || Misrepresented: Case Law | Claimed McQueen supports that indictment ambiguities or omissions violating preparation or double-jeopardy interests violate the Sixth and Fifth Amendments, which McQueen does not support. || False Quotes: Case Law | Falsely quoted Veal as forbidding courts from ignoring statutory definitions in favor of dictionary meanings. || False Quotes: Case Law | Falsely quoted Wisconsin Right to Life with a definition of as-applied challenges not found in the opinion. || False Quotes: Doctrinal Work | Attributed to a 1968 Senate Report

In re Thomas Grant Neusom

O’Brien v. Flick and Chamberlain

Fabricated: Case Law | Plaintiff cited Snyder v. City of Sanford, 645 So. 2d 1126 (Fla. 5th DCA 1994), which the Court determined does not exist after its own search and relied on in imposing sanctions. || Fabricated: Case Law | Plaintiff cited Valley Nat’l Bank of Arizona v. A.E. Moses, 617 So. 2d 455 (Fla. 4th DCA 1993), which the Court determined does not exist after its own search and relied on in imposing sanctions.

Florida Senate Bill 1680

Creates the Government Technology Modernization Council to study AI and technology, recommend regulations, assess AI's legal effects, and propose ethics reforms. Requires annual legislative recommendations to modernize technology and protect against AI misuse. Prohibits creation and possession of generated child pornography.

Florida House Bill 919

Requires political ads using generative AI to include a disclaimer. Specifies disclaimer format based on media type. Imposes first-degree misdemeanor for non-compliance. Authorizes complaints to the Florida Elections Commission with expedited hearings. Effective July 1, 2024.

Miami Dade County Artificial Intelligence Report: Policies, Principles & Guidelines

Requires Miami-Dade County employees under the Mayor to use artificial intelligence (AI) tools ethically and responsibly. Instructs the Human Resources (HR) and Information Technology Departments (ITD) to provide necessary training and oversight. Directs ITD to oversee AI procurement, deployment, and data security. Establishes guidelines for AI training, risk assessments, data handling, and community engagement, ensuring compliance with privacy and ethical standards.