| Court - Judge Name | Applicable To | Categories |
Summary |
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| S.D. Fla. – Magistrate Judge Panayotta Augustin-Birch | 12/2/2025 | Generative AI | Generative AI Usage | In Button v. McCawley, 2025 U.S. Dist. LEXIS 234737 (S.D. Fla. Dec. 2, 2025), the pro se plaintiffs cited numerous GenAI-hallucinated cases in their response to the defendant's motion for attorney's fees. Magistrate Judge Augustin-Birch noted that the plaintiffs “falsely attribute[d] quotes” and “cite[d] non-existent cases.” The court ultimately decided not to recommend imposing sanctions because of the plaintiffs’ pro se status and the fact that it was their first infraction. However, the court warned that “going forward, Plaintiffs must ensure that all of their caselaw quotations and citations are accurate.” Magistrate Judge Augustin-Birch recommended granting the motion in part and denying it in part on other grounds. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| M.D. Fla. – Judge Paul G. Byron | 12/2/2025 | Generative AI | Generative AI Usage | In Ford v. James Koutoulas & Lgbcoin, Ltd., 2025 U.S. Dist. LEXIS 234696 (M.D. Fla. Dec. 2, 2025), the defendants' motion for summary judgment contained several citations that the court and the plaintiffs suspected were GenAI hallucinations, where the court was “unable to locate” the cited authorities. The defendants did not deny plaintiffs’ allegations that their filings contained AI hallucinations. Judge Byron noted that citing to nonexistent cases is a “misrepresentation to the Court,” is sanctionable under Fed. R. Civ. P. 11, and violates the Florida local rules and rules of professional conduct. The court warned that continued “unethical practices” may result in sanctions. The court denied the defendants' motion on other grounds. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| M.D. Fla. – Judge William F. Jung | 12/1/2025 | Generative AI | Generative AI Usage | In Bey v. Glass, 2025 U.S. Dist. LEXIS 233422 (M.D. Fla. Dec. 1, 2025), the pro se plaintiff cited a nonexistent case in his complaint. Judge Jung suspected that the hallucinated citation was the result of GenAI use in drafting after the court “cannot find . . . based on independent research” a case the plaintiff cited and warned the plaintiff that the court has the “inherent authority” under Fed. R. Civ. P. 11 to impose sanctions for GenAI use, “including the complete dismissal and termination of the case.” The court dismissed the plaintiff's complaint without prejudice on other grounds. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| M.D. Fla. – Judge Sheri Polster Chappell | 11/26/2025 | Generative AI | Generative AI Usage | In Doc App, Inc. v. Leafwell, Inc., 2025 U.S. Dist. LEXIS 232188 (M.D. Fla. Nov. 26, 2025), the court granted the defendant’s motion for sanctions after the plaintiff’s counsel included various inaccurate citations (including to nonexistent and out-of-context cases) in its motion for a temporary restraining order and preliminary injunction. The court found that the plaintiff’s attorney violated Federal Rule of Civil Procedure 11(b) for including erroneous citations due to his “reckless use of AI.” The court concluded that sanctions were particularly warranted where counsel responded to the court’s order to show cause in a “colossal [] collection of excuses and projection” with a “defiant tone and condescending communications with and about his opposing counsel,” and where plaintiff’s counsel was not forthcoming about his use of AI. Judge Chappell held that the attorney failed to take responsibility for his actions and reminded him of his role as “an officer of the court” with “a duty of candor to the tribunal.” As sanctions, Judge Chappell ordered plaintiff’s counsel to: (i) pay the defendant’s attorneys’ fees and costs associated with their response to the motion; (ii) file a copy of this order to any complaint filed in the next 2 years in the Middle District of Florida; (iii) attend a Florida CLE class on legal ethics and AI by January 30, 2026 and file a certificate of completion by February 20, 2026; and (iv) send a copy of this order to his client’s CEO and file an affidavit confirming that the CEO has read the order. The court also referred plaintiff’s counsel to the Florida Bar for “appropriate discipline” and asked the clerk to send the entire case record to the Florida Bar. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Attorneys/Law Firms | ||||
| S.D. Fla. – Magistrate Judge William Matthewman | 11/21/2025 | Generative AI | Generative AI Usage | In Clayman v. Bessant, 2025 U.S. Dist. LEXIS 232878 (S.D. Fla. Nov. 21, 2025), the pro se plaintiff admitted that the only cited case in his motion to alter or amend an order was an “AI-generated hallucination.” The court noted that the plaintiff is permitted to use AI for drafting assistance but must ensure that all cases are accurate. Judge Matthewman also provided a “final warning” that the plaintiff could face sanctions and a restricted filing if he continues to misuse AI. The court ultimately denied plaintiff’s motion to alter or amend a judgment. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| S.D. Fla. – Judge Rodolfo A. Ruiz II | 11/21/2025 | Generative AI | Generative AI Usage | In Dubinin v. Papazian, No. 25-CV-23877-RAR, 2025 U.S. Dist. LEXIS 229362 (S.D. Fla. Nov. 21, 2025), following the court’s orders to show cause why plaintiff’s counsel should not be sanctioned for “cites to non-existent cases and quotations in a brief that appeared to be drafted using [GenAI],” plaintiff’s attorney denied using AI, but “admitted to filing a brief riddled with inaccuracies,” claiming the drafting had been delegated to another attorney. The court reviewed the two attorneys’ other filings in different matters and found that the two attorneys had previously been caught submitting filings that “may have been drafted using [GenAI].” Because of the filing attorney’s “misconduct in this case and others, including her misrepresentations to the Court,” and the fact that her “use of AI was ‘so egregious that this Court finds that [it was] done in bad faith,’” the court concluded that sanctions are appropriate under the court’s inherent powers, Local Rule 6(b)(2)(A) of the Southern District of Florida, and 28 U.S.C. § 1927. The court ultimately struck plaintiff’s complaint and dismissed the action without prejudice, ordered the filing attorney to pay defendant’s attorney fees, and referred both the filing and drafting attorneys to the Florida Bar and Grievance Committee. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Attorneys/Law Firms | ||||
| M.D. Fla. – Judge Steven D. Merryday (Nov. 12, 2025) | 11/12/2025 | Generative AI | Generative AI Usage | In Bey v. Apple Inc., 2025 U.S. Dist. LEXIS 222566 (M.D. Fla. Nov. 12, 2025), a pro se plaintiff “either used artificial intelligence or fabricated case law” in his opposition brief to the defendant’s motion to dismiss. In particular, the plaintiff cited a “non-existent case” and “misstate[d] the holdings of several cases.” While the motion to dismiss was granted on other grounds, Judge Merryday warned the plaintiff that further GenAI hallucinations or fabrications will result in monetary or other sanctions. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| S.D. Fla. -- Judge William Matthewman | 10/16/2025 | Generative AI | Generative AI Usage | In Manisero v. Bradshaw, 2025 U.S. Dist. LEXIS 204328 (S.D. Fla. Oct. 16, 2025), the defendant claimed that the plaintiff included erroneous citations in his opposition to the defendant’s motion to dismiss, which the court stated “implies the inappropriate use of Artificial Intelligence.” While the motion to dismiss was granted and denied in part on the merits, Judge Matthewman cautioned the plaintiff of the need to “supervise the AI” to ensure that there are “no hallucinated citations or quotations,” tp the extent that these tools are used to “aid him in drafting his filings,” as sanctions could be imposed for further inclusion of hallucinated materials. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| Fla. Dist. Ct. App. – Per Curiam (Chief Judge Matthew C. Lucas, Judge Morris Silberman, Judge Craig C. Villanti) | 8/29/2025 | Generative AI | Generative AI Usage | In Clerk of the Ct. & Comptroller for the 13th Jud. Cir. v. Rangel, 2025 Fla. App. LEXIS 6597 (Fla. Dist. Ct. App. Aug. 29, 2025), the appellant identified various citations “that do[] not appear to exist” and other misrepresentations of case law in the appellee’s answer brief. In response to the court’s order to show cause, the appellant’s attorney admitted to hiring an “independent contractor paralegal to assist in drafting the answer brief,” failing to check any of the authority cited prior to the filing, and including “non-existent authority and fictitious quotation blocks” in the brief. Further, the attorney stated that he did not review the appellee’s reply brief that identified these errors. The attorney requested a sanction of completing CLE courses and 100 hours of pro bono work. The Court of Appeal of Florida agreed that sanctions are appropriate but referred the matter to The Florida Bar “for appropriate disciplinary proceedings and sanctions as are deemed proper” and permitted the appellant’s attorney to submit an amended answer brief and hold oral argument at a later date. The per curiam opinion served as “another reminder that an attorney who does so remains responsible for the work product that is generated.” |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Attorneys/Law Firms | ||||
| S.D. Fla. – Magistrate Judge Panayotta Augustin-Birch | 8/14/2025 | Generative AI | Generative AI Usage | In Monster Energy Co. v. Owoc, No. 24-cv-60357, ECF No. 54 (S.D. Fla. Aug. 14, 2025), the pro se defendant included eleven citations “suspected of being fake citations hallucinated by artificial intelligence” in his opening brief and reply in support of his motion to enforce the one satisfaction rule and bar additional collection. During a hearing on the court’s order to show cause, the defendant admitted to using GenAI to create those citations given his financial difficulties and related inability to access paywalled legal research tools. Id. at 1. The defendant then submitted an amended opening brief and reply that was allegedly reviewed by an attorney to ensure the citations’ accuracy. Id. at 1-2. Although the court appreciated the defendant’s honesty, apology, and steps towards remediation, the court required the defendant to (i) “complete 10 hours of community service with a non-profit organization of his choice” and submit documentation from the organization to verify his attendance and (ii) include disclosures in future filings as to whether any GenAI tool was used and that all included citations are accurate. Id. at 3. Magistrate Judge Augustin-Birch found monetary sanctions to be inappropriate in this case since the defendant has only submitted two filings with hallucinated citations. Id. at 2. |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| S.D. Fla -- Magistrate Judge Lisette M. Reid | 7/24/2025 | Generative AI | Generative AI Usage | In Nunez v. Am. Airlines, Inc., 2025 U.S. Dist. LEXIS 141848 (S.D. Fla. July 24, 2025), in a report and recommendation, the magistrate judge recommended a pro se plaintiff’s complaint be dismissed with prejudice on the merits and separately as a result of plaintiff’s “continued willful violations of the Local Rules and for submitting fake caselaw to the Court.” Along with other repeated violations of the court’s local rules, plaintiff submitted two instances of fake caselaw in his opposition to defendant’s motion to dismiss. After defendant pointed this out in their reply, the plaintiff submitted an “improper” sur-reply (which itself did not correct the false citations) “by largely attacking Defendant for pointing it out, and by attempting to brush off the usage as an ‘unintentional and correctable . . . formatting or citation error.’” |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| S.D. Fla. – Judge David S. Leibowitz | 7/17/2025 | Generative AI | Generative AI Usage | In Byoplanet International, LLC v. Gilstrap, No. 0:25-cv-60647-DSL (S.D. Fla. July 17, 2025), the plaintiff’s attorney admitted to repeatedly including hallucinated citations in 8 “separate but related” cases in state and federal court, 4 of which were before Judge Leibowitz. See ECF No. 33 at 1, 4. During a hearing on the court’s order to show cause as to whether the attorney’s repetitive use of AI was done in bad faith, plaintiff’s counsel divulged that he relied on his paralegal for performing assertion checks and did not conduct his own due diligence into the accuracy of his cited authority. Id. at 9. Despite the attorney’s remorse, Judge Leibowitz found that his actions “constitute[d] repeated, abusive, bad-faith conduct that cannot be recognized as legitimate legal practice” in violation of the Federal Rules of Civil Procedure and the Southern District of Florida’s Local Rules. See id. at 10, 20-21. The court focused on the attorney’s use of AI after being on notice that his tool produced hallucinated citations and the attorney’s sole reliance on a non-attorney to draft certain filings without a post-hoc review. See id. at 15-17. As such, the court (i) ordered the dismissal of the four cases pending before him without prejudice, (ii) ordered the plaintiff’s attorney to pay defendants’ attorneys’ fees associated with any response to a filing generated by AI, (iii) required the plaintiff’s attorney to attach a copy of this order to any filing of a new case in this district within the next two years, and (iv) referred the plaintiff’s attorney to the Florida Bar. Id. at 20-21. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Attorneys/Law Firms | ||||
| S.D. Fla. – Magistrate Judge William Matthewman | 7/11/2025 | Generative AI | Generative AI Usage | In Crespo v. Tesla, Inc., 2025 U.S. Dist. LEXIS 134498 (S.D. Fla. July 11, 2025), following the court’s June 30, 2025 order on the motion to strike filings with AI-generated cases, the court found it appropriate for the pro se plaintiff to pay $921.00 out of the requested $1,096.00 in defendant’s attorney fees associated with the review of the hallucinated citations and briefings. Judge Matthewman declined to award the full requested amount after finding that some tasks amongst the attorneys were duplicative of each other. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| S.D. Fla. – Magistrate Judge William Matthewman | 6/30/2025 | Generative AI | Generative AI Usage | In Crespo v. Tesla, Inc. et al., 2025 WL 1799411 (S.D. Fla. June 30, 2025), the defendant moved to strike the pro se plaintiff’s reply briefs in support of his various motions to compel because the plaintiff included citations to nonexistent authority. The plaintiff’s sole reason for the hallucinated citations was a “flawed workflow process,” though he accepted responsibility for the erroneous submissions. The court ultimately required the plaintiff to submit a written apology to the defendant’s counsel for the frustrations and wasted time associated with reviewing the cited authorities and pay the defendant’s attorneys’ fees associated with this review. Magistrate Judge Matthewman warned that the sanctions being considered “would be much more serious” had the plaintiff not been honest about his use of AI. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| M.D. Fla -- Judge Mary S. Scriven | 6/13/2025 | Generative AI | Generative AI Usage | In Hsien Chueh Yao v. Univ. of S. Fla. Bd. of Trs., 2025 U.S. Dist. LEXIS 113006 (M.D. Fla. June 13, 2025), the court struck a pro se plaintiff’s briefs after the defendant alleged that the plaintiff used artificial intelligence to draft both the original and corrected opposition briefs because of numerous instances of citations by the plaintiff to nonexistent or inapplicable caselaw. Plaintiff was notified of the nonexistent citations in the original opposition, but did not properly amend the citations to caselaw that supported his legal claims. As a result, the court struck both oppositions, but allowed the plaintiff fourteen days to file a renewed opposition, cautioning that failure to cite “real cases that support the propositions for which they are cited will result in the imposition of sanctions.” |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| S.D. Fla. -- Judge William Matthewman | 5/20/2025 | Generative AI | Generative AI Usage | In Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enterprises LLC, 2025 WL 1440351, defense counsel included a non-existent case citation in a discovery-related briefing. Once plaintiff’s counsel identified the issue, the court ordered defense counsel to provide an explanation for the citation, to which they admitted to their use of (and unfamiliarity with) an AI tool to assist with research and failure to check the accuracy of their citation. Ultimately, the court ordered defense counsel to pay the plaintiff’s attorneys’ fees and costs associated with verifying the citation, pay a $1,500 fine, and attend a continuing legal education program on ethical considerations when using AI. The court advised that attorneys “carefully evaluate, elucidate, and advocate – not hallucinate” and criticized defendants’ counsel for failing to double check the citations used. The court emphasized that “pleadings, motions, responses, replies, and other papers filed with any Court must be first checked and then double-checked. . . . [T]he submission of fake, hallucinated case citations, facts, or law . . . . is entirely preventable by competent counsel who do their jobs properly and competently.” However, the court did appreciate the attorneys’ remorse and noted that any attempt to cover up their behavior would have warranted more serious sanctions. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Attorneys/Law Firms | ||||
| M.D. FL - Judge Schlesinger | 12/19/2024 | Generative AI | Generative AI Usage | This scheduling order by Judge Schlesinger in Soehlig v. Experian Information Solutions, Inc. requires disclosure and a certification if “AI” (used as shorthand in the order for “generative artificial intelligence”) is used for any filings. Litigants must specifically identify the specific AI used and “the part of the filing drafted by AI,” while also certifying that the “AI work product was diligently reviewed by a human for accuracy and applicability.” The court also states that Gen AI alone cannot be relied upon to ensure compliance with Rule 11 of the Federal Rules of Civil Procedure’s reasonableness requirements, further clarifying the court’s expectation of careful review of any Gen AI-related material submitted. |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Filings/Drafting | ||||
| 17th Judicial Circuit, Florida – Administrative Order | 12/5/2024 | Any AI | Any AI Usage | The 17th Judicial Circuit’s Uniform Case Management Order (Exhibit B) requires both attorneys and pro se parties to “disclose the use of artificial intelligence on the face” of any filing and certify that they have “personally reviewed and verified the content’s accuracy.” Additionally, attorneys must ensure that any AI use does not violate ethical obligations to Florida state law and the Florida Bar. A failure to comply with these requirements may result in sanctions. |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Filings/Drafting | ||||
| M.D. Fla. – Judge John E. Steele | 3/8/2024 | Any AI | Any AI Usage | In In re Neusom, 2024 WL 1013974 (M.D. Fla., Mar. 8, 2024), the court adopted the findings of a grievance committee that an attorney violated multiple rules of professional conduct by submitting legal filings containing inaccurate and fabricated authorities, some of which were generated using artificial intelligence tools. The investigation revealed that the attorney failed to “conduct reasonable diligence and provide accurate legal authority to the Court” where the attorney admitted that “‘he used Westlaw and FastCase and may have used artificial intelligence to draft the filings(s) but was not able to check the excerpts and citations.’” 2024 WL 982508, at *4 (M.D. Fla. Jan. 11, 2024). The grievance committee also found that the attorney had provided “unprofessional” responses when questioned about his authorities. Id. at *5. Based on these findings, the court suspended the attorney from practicing in the Middle District of Florida for one year and imposed strict conditions for reinstatement, including completing specified CLE courses, counseling, and certifying review of professional conduct rules. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Attorneys/Law Firms |
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