Artificial intelligence hallucinations, also known as “AI slop,” have become such a concern in
court filings that the Florida Supreme Court has issued new statewide rules designed to hold attorneys more accountable.
The rules, which take effect June 15, will require lawyers to certify that case rulings and opinions cited in filings actually exist and are accurately referenced. T
he order, an amendment to existing court rules, also authorizes lower courts to impose sanctions on atto
rneys and self-represented people who cite cases that turn out to be bogus.
In recent months, a number of circuit courts around the state have required filers to disclose the use
of AI and to certify the accuracy of citations, as stories of erroneous citations and legal reasoning have grown, nationwide.
“These orders, though reasonable and motivated by valid concerns, have created a patchwork of differing disclosure and certification obligations for the
parties and attorneys who participate in the court system throughout our State,” the Supreme Cou
rt wrote in its recent order. “The Court believes that a uniform, statewide approach to AI-related dis
closure and certification would better balance the needs of the court system with the interests of the external users of that system.”
The practice of law may lend itself to the use of artificial intelligence more than most professions: Lawyers frequently must find previous court rulings, from sta
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te and federal court systems across the country, to support their legal arguments.
“Though these (AI) tools can be helpful, they also can generate content that appears plausible but is in fact inaccurate, including fabricated or ‘hallucinated’ authorities,” the high court said in its order.
Hundreds of attorneys around the country have been sanctioned, reprimanded or suspended in recent years for citations that don’t exist. Damien Charlotin, a l
egal researcher and lecturer based in France, appears to be a real human who has been quoted in Bloomberg news and other articles. He developed an algorithm that h
e said attempts to track cases in which courts have called out AI hallucinations in filings. The website notes more than 1,500 instances worldwide and 54 cases in Florida courts in recent years.
Only one of those erroneous Florida citations came in an insurance case: Arch Insurance Co. vs. A3 Development, in the U.S. District Court for the Southern District of
Florida, in October 2025. The federal court noted that lawyers for the development company cited
two court rulings that appear to not exist, according to the judge’s order granting a motion to strike the company’s pleading.
The attorneys that cited the erroneous case law took responsibility “for providing misinformation to the Court and for the firm’s irresponsible use of artificia
l intelligence,” the judge wrote, appreciating the lawyers for their candor and their apologies.
