Что изменилось

3 See, e.g., Avery v. Beauzil, 51 Fla. L. Weekly D1068 (Fla. 4th DCA May 27, 2026) (barring a pro se litigant from future filings due in part to AI hallucinations in filings); Gleason v. Marcus, 432 So. 3d 1265, 1265– 66 (Fla. 2d DCA 2026) (cautioning on the dangers of using generative AI without confirming the results); Rodriguez v. Rodriguez, 51 Fla. L. Weekly D771 (Fla. 6th DCA Apr. 10, 2026) (ordering attorney to show cause why she should not be sanctioned for filing a petition for a writ of certiorari containing AI hallucinations); Gouveia v. Meridian Fin. Invs., LLC, 432 So. 3d 49, 50–51 (Fla. 4th DCA 2026) (warning a pro se party against using generative AI without verifying the results in any future filings); Hessert v. Hessert, 431 So. 3d 610, 615 (Fla. 6th DCA 2026) (ordering a party to show cause why she should not be sanctioned for AI hallucinations in her petition for a writ of certiorari); Russell v. Mells, 426 So. 3d 913, 920 (Fla. 2d DCA 2025) (referring attorney to The Florida Bar for AI hallucinations); Takefman v. Pickleball Club, LLC, 418 So. 3d 826, 826– 27 (Fla. 3d DCA 2025) (warning about the use of generative AI without verifying the results); Goya v. Hayashida, 418 So. 3d 652, 656 (Fla. 4th DCA 2025) (warning a pro se party who had filed a "counterfeit brief" based on AI hallucinations); Rangel, 427 So. 3d at 1071–72 (referring attorney to The Florida Bar for AI hallucinations); Gutierrez v. Gutierrez, 399 So. 3d 1185, 1188 (Fla. 3d DCA 2024) (imposing sanctions on a pro se litigant for submitting a brief that included "fictitious case law").

Inc., 168 F.4th 231, 235 (5th Cir. 2026) ("If it were ever an excuse to plead ignorance of the risks of using generative AI to draft a brief without verifying its output, it is certainly no longer so."); see also United States v. McGee, 806 F. Supp. 3d 1264, 1275 (S.D. Ala. 2025) ("Given the broad attention . . . to the problem with AI generated cases and authorities, no attorney can claim ignorance or simply bury their head in the sand when it comes to their own use of AI (regardless of what program they use).").

• Repeatedly citing Maciejewski v. Holland, 441 So. 2d 703 (Fla. 2d DCA 1983), a two-page opinion explaining why the complaint there stated a cause of action for declaratory relief, for unrelated propositions such as that "[u]nder Florida law, a party's actions that affirm the validity of a transaction preclude subsequent challenges to that

• Serving up nonexistent quotes—complete with purported pincites—such as, "[fundamental error] goes to the foundation of the case or the merits of the cause of action and is equivalent to a denial of due process," citing Hart Properties, Inc. v. Slack, 159 So. 2d 236, 239 (Fla. 1963).

• Passing off Miami Country Day School v. Bakst, 641 So. 2d 467 (Fla. 3d DCA 1994), a case discussing the statutory mechanics of whether a houseboat qualified for a homestead exemption, as authority for a panoply of propositions, including that "Florida law provides strong protections to individuals who acquire property in good faith, for valuable consideration, and without notice of competing claims" and that "a party's delay or misleading conduct bars recovery where another party suffers detriment as a result."

• Relying on Gonzalez v. Deutsche Bank National Trust Co., 95 So. 3d 251 (Fla. 2d DCA 2012), a case pertaining to the adequacy of an undated assignment to confer standing, as an all-purpose authority on a multitude of other subjects, including that "substantive evidence, not speculation, is needed to rebut possession-based presumptions" and that "good faith reliance on recorded documents is sufficient to establish bona fide purchaser status."

Admin. 2.515(d)(2). But that certification is patently false when an argument in the brief is based on AI hallucinations. See Hessert v.

and noting that "Florida's appellate courts, like other courts, require pro se litigants and attorneys to sign their filings and thereby represent the accuracy thereof"); see also Russell v. Mells, 426 So. 3d 913, 920 (Fla. 2d

Indeed, we "reject[ ] any . . . notion that because some authority exists to support a legal proposition it should negate the harm caused by false and hallucinated cases. Put bluntly—absolutely not; period; end of story; all stop." McGee, 806 F. Supp. 3d at 1273; see also Russell, 426

Further, filings that include AI hallucinations force the judiciary and its staff to waste time sloshing through bilge rather than analyzing cases on their merits. At bottom, they gut an appellate court's ability to rely on counsel to set out in the first instance the applicable law governing a dispute. See Azar v. Garza, 584 U.S. 726, 730 (2018) (noting the importance of "lawyers and courts alike be[ing] able to rely on one another's representations"); Boca Burger, Inc. v. Forum, 912 So. 2d 561,