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Florida · state appellate court · 2025

Russell v. Mells

District Court of Appeal of Florida, 10 December 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Fla. Dist. Ct. App.

  1. Court. District Court of Appeal of FloridaCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 10 December 2025DATED
  4. Docket. No. 2D2024-1560DOCKET
  5. Documents. one document, 5 passages quoted belowON FILE
  6. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 10 December 2025 · source · PDF · 12 pages

8 Because the "Cade v. Roberts" case citation appeared to have been "hallucinated" (most likely by a generative artificial intelligence program)3 and because the other two case citations contained misquotations, we issued an order to show cause to appellee's counsel. In our order, we directed counsel to file a written response explaining how these case citations and quotations were generated.

23, 2025, 7:44 PM), https://www.wired.com/story/google-ai-overviews-meaning/). According to one study, GenAI programs for legal research hallucinate legal authorities between seventeen and thirty-three percent of the time. See Varun Magesh, Faiz Surani, et al., Hallucination-Free?

Before becoming appellate or trial judges, we practiced in state and federal courts in a wide variety of cases throughout the State of Florida. None of us can recall an instance when an attorney accidentally submitted a completely fabricated case as a legal authority to a court of law—not until the recent advent of generative artificial intelligence. Unfortunately, we're finding this problem arising more and more frequently.

3d 1185, 1187–88 (Fla. 3d DCA 2024) (imposing sanctions on a pro se litigant for failing to comply with Florida Rule of Appellate Procedure 9.210(b) and for submitting a brief that included "fictitious case law"); ByoPlanet Int'l, LLC v. Johansson, No.

Fla. May 20, 2025) (concluding that sanctions were appropriate when attorneys submitted a written response containing "a fake hallucinated case citation which allegedly supported a principle of law for which they were advocating"). 2025 WL 2486314, at *2.

What the text mentions

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Where this fits

This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.

More from District Court of Appeal of Florida, from Florida, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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