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Florida · state appellate court · 2026

Sean Ryan v. Alina Perez

District Court of Appeal of Florida, 23 September 2026. 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. 23 September 2026DATED
  4. Docket. No. 3D2025-1254DOCKET
  5. Documents. one document, 4 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, 23 September 2026 · source · PDF · 4 pages

We conclude that the arguments presented lack merit and that competent, substantial evidence supports the trial court’s determinations.1 We therefore affirm without further discussion on the merits. But we write to address the fact that the initial brief relied extensively on hallucinated case cites ( to either nonexistent cases or cases that are miscited and, in any event, do not support the legal proposition for which they are proffered). The answer brief details no fewer than ten hallucinated cases.

3d 1185, 1188 (Fla. 3d DCA 2024) (“ We find Gutierrez ’s failure to comply with rule 9.210(b) and submission of fictitious case law to this court sufficient to 1 See Garnett v. Duvalsaint , 400 So.

The problem here is exacerbated by the fact that the self-represented appellant is a member of the Florida Bar. The “proliferation of fake or hallucinated case citations in court filings ” is “an issue of growing concern,” and “[w]e aren’t the only court in Florida [or elsewhere] to address this problem.” Takefman v. Pickleball Club, LLC, 418 So.

2 Ryan’s motion seeking leave to file a corrected initial brief attempts to explain the errors that resulted in filing the initial brief with hallucinated citations.

What the text mentions

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Where this fits

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More from District Court of Appeal of Florida, from Florida, or from 2026. 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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