After using generative AI and not checking its outputs in eight related cases, a Florida lawyer has received severe sanctions.

In the case available here via Damien Charlotin’s AI hallucinations site (hat tip to Maura R. Grossman for the heads up on the case), Florida District Judge David S. Leibowitz opened his order by stating this:

“‘The integrity of judicial proceedings depends upon the ethical obligations of candor and honesty being strictly observed by all parties.’ Liteky v. United States, 510 U.S. 540 (1994) (Scalia, J., concurring).

Two things: (1) The above statement is absolutely correct. (2) the great Justice Antonin Scalia did not write this anywhere in his Opinion of the Court (not concurring) in Liteky. A quick review of the U.S. Reports confirms that. But ChatGPT, with the slick, cool authority of instantly-generated pixels on a screen, declares otherwise. Artificial intelligence, indeed.”

The order addresses the misuse of AI by attorney James Martin Paul, who repeatedly submitted fabricated legal citations and quotations generated by AI in multiple court filings across not one, not two, but eight related cases! In it, Leibowitz outlines how Paul’s actions, including his stated reliance on a paralegal to draft documents without verifying the AI-generated content, violated professional duties under Federal Rule 11, the court’s inherent authority, local rules, and U.S. Code § 1927.

Notably, Paul was explicitly put “on notice that his use of AI was leading to hallucinated cases and quotations” as early as April 25, 2025, when a defendant moved to dismiss a complaint based on incorrect references. Despite this, Paul “submitted seven filings to this Court and other courts after this date that contained hallucinated cases and fabricated quotations, including in a response to an order to show cause regarding his use of AI to generate hallucinated cases and quotations.”

I have no words.

So, what were the sanctions for Paul’s “repeated, abusive, bad-faith conduct that cannot be recognized as legitimate legal practice and must be deterred”? They were:

• Dismissal of Cases: The four cases before the court (and any related refiled cases assigned to the same judge) were “DISMISSED without prejudice and without leave to amend.”
• Monetary Sanctions: Paul was “ORDERED to pay the attorneys’ fees for Defendants’ counsel in these four cases for all time spent responding to any filing in which generative AI was used to develop hallucinated cases and fabricated quotations.”
• Future Filing Requirement: If Paul files any case in the Southern District of Florida within the next two years, he “must attach a copy of this Order to his Complaint.”
• Referral to The Florida Bar: Paul is “HEREBY REFERRED to the Florida Bar for appropriate discipline.”

Ouch! Clearly, judges are no longer tolerating AI hallucinations in case filings as we are up to 224 cases with them per the AI hallucinations site. Especially when the violations are this egregious.

So, what do you think? Can you believe this lawyer submitted filings in eight related cases with AI hallucinations? Please share any comments you might have or if you’d like to know more about a particular topic.

Image created using GPT-4o’s Image Creator Powered by DALL-E, using the term “robot judge doing a faceplant when looking at a computer”.

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