More local AI-related news as administrative orders have come out sanctioning attorneys.
In Multiphone Latin America, Inc. v. Millicom International Cellular S.A., No. 25-cv-23249, Chief Judge Altonaga found that the brief cited two hallucinated Florida appellate cases that appear not to exist and quoted language absent from the cases it cited. The lawyers’ proposed sur-reply then misquoted more cases, in places presenting Westlaw headnotes as quotations from the opinions themselves.
In Dubinin v. Papazian, No. 25-cv-23877, Judge Ruiz identified at least ten fabricated or misrepresented citations and quotations in the plaintiff’s complaint and response brief. The Florida lawyer who signed it said a New York lawyer had drafted it. The New York lawyer had never appeared or sought pro hac vice admission, and she said a legal assistant had used AI.
Administrative Order 2026-87 and 2026-95 referred the lawyers in those cases to the Peer Review Committee and The Florida Bar. The lawyers had to take CLEs, pay monetary sanctions, and write letters of apology. Continuing moral of the story is do not be “that guy” (or gal). As in Dubinin, do not rely on out-of-state counsel to ensure compliance with the rules.
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