The attorney remains unnamed in available reports. The appeals court's identification of the fabricated citations occurred recently, with the referral announcement coming on April 10, 2026. The specific details of the filings and the court's findings have not been made public.
The case mirrors a 2024 federal precedent in which a lawyer was sanctioned for citing 26 fabricated or misrepresented cases in pleadings, violations of Florida Rules of Professional Conduct 4-3.3(a)(3) (candor toward the tribunal) and 4-8.4(c) (dishonesty). That incident also involved possible AI assistance. The current matter underscores a widening problem: attorneys deploying AI tools without adequate verification protocols. As legal adoption of generative AI accelerates, so too does the risk of AI "hallucinations"—fabricated case law, statutes, and citations that appear plausible but do not exist. Courts and bar associations are beginning to enforce existing ethics rules against these practices, but the regulatory framework remains unsettled. Practitioners should implement mandatory citation verification procedures before filing and consider whether their malpractice insurance covers AI-related errors.