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.
Docket entry 45, 3 December 2025 · source · PDF · 3 pages
Docket text. ORDER Dismissing Case (With Prejudice), granting 44 Defendant's MOTION [Motion to Modify Order] re 42 Order Dismissing/Closing Case, filed by Charles Gilstrap. Case Closed. Motions terminated: 44 Defendant's MOTION [Motion to Modify Order] re 42 Order Dismissing/Closing Case filed by Charles Gilstrap. Signed by Judge David S. Leibowitz on 12/2/2025. See attached document for full details. (pc) (Entered: 12/03/2025)
0:25- cv-60630 unless otherwise stated. Case 0:25-cv-60630-DSL Document 45 Entered on FLSD Docket 12/03/2025 Page 1 of 3 without prejudice and ordered Paul to pay the attorneys’ fees of Defendants’ counsel for time spent responding to filings in which generative artificial intelligence (“AI”) was used to develop hallucinated cases and fabricated quotations. [ Id. at 20].
Docket entry 43, 1 August 2025 · source · PDF · 10 pages
Docket text. ORDER: Regarding Disputed Fee Amounts and Proposed Payment Plan. Signed by Judge David S. Leibowitz on 7/31/2025. See attached document for full details. (pc) (Entered: 08/01/2025)
21]. As relevant here , the Court ordered Paul to pay Defendants’ counsel “ for all time spent responding to any filing in which generative AI was used to develop hallucinated cases and fabricated quotations.” [Id. at 20]. The Court further ordered the parties to confer and attempt in good faith to reach agreement on Defendants’ attorneys’ fees and costs in this regard .
[See id. ¶ 5 (stating that Paul “has not been compensated for his services to date ” in this matter and that he has “limited financial resources”)]. As for the latter, Paul cites to a private database of AI hallucination sanctions cases to Case 0:25-cv-60630-DSL Document 43 Entered on FLSD Docket 08/01/2025 Page 7 of 10 argue that “the above-referenced proposal would be the largest sanctions paid out for the use of AI generative case law to date .” [ Id. ¶ 6 (citing Damien Charlotin, AI Hallucination Cases, https://www.damiencharlotin.com/hallucinations (last visited July. 31, 2025) (“the AI Sanctions Database”)].
Case 0:25-cv-60630-DSL Document 43 Entered on FLSD Docket 08/01/2025 Page 8 of 10 Second, and relatedly, even if the Court were to accept that an award of fees and costs here may be greater than in other AI sanction cases, Paul does not contend with the fact that orders awarding fees and costs in cases involving the misuse of AI appear nearly unanimous in tying those awards to the time spent responding to papers supported by AI hallucinations.
Docket entry 42, 16 July 2025 · source · PDF · 21 pages
Docket text. Order Closing Case. (Without Prejudice) Motions terminated: 40 Defendant's MOTION to Stay Discovery Pending Disposition of Pending Motions to Dismiss filed by Peter Johansson, 39 Unopposed MOTION to Consolidate Cases and to Stay Discovery filed by Charles Gilstrap, 24 Defendant's MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM or in the alternativeDefendant's MOTION to Dismiss for Lack of Jurisdiction or in the alternative, Motion to Compel Arbitration filed by Peter Johansson, 31 Defendant's MOTION TO DISMISS 1 Complaint FOR FAILURE TO STATE A CLAIM filed by Charles Gilstrap. Signed by Judge David S. Leibowitz on 7/15/2025. See attached document for full details. (pc) (Entered: 07/17/2025)
When a lawyer presents false information to a court, that lawyer violates his duties. This case presents an important issue (unfortunately one that is occurring more often): what sanctions should a court impose on a lawyer who repeatedly uses false, fake, non-existent, AI-generated legal authorities in the drafting of complaints, motions, and other filings ? Here, Plaintiffs’ counsel repeatedly regurgitated such “hallucinated” authority in eight separate but related cases.
However, AI is not yet a match for an actual litigator. Employing the euphemism-du-jour, AI regularly “hallucinates” entire cases and “hallucinates” quotations from real cases. See Sara Merken, AI ‘hallucinations’ in court papers spell trouble for lawyers , Reuters, https://www.reuters.com/technology/artificial-intelligence/ai-hallucinations-court-papers-spell- trouble-lawyers-2025-02-18/ (noting AI’s “penchant for generating legal fiction in case filings[.]”).
Timeline of Events 2 Beginning in March of 2025, James Martin Paul, Esq. (“Paul”), counsel for the Plaintiffs in the above-captioned cases and four other related cases filed in Florida courts (eight cases in total) , repeatedly used AI to hallucinate cases and quotations in his filings . Indeed, Paul admitted to using generative AI and not checking its outputs in each of the eight related cases.
On March 12, 2025, Paul filed a Complaint in the Circuit Court of the Seventeenth Judicial Circuit in and for Broward County, Florida (“the O’Shea Complaint”), Case No. CACE -25-003491, on behalf of Richard Patrick Michael O’Shea (“O’Shea”).3 In the O’Shea Complaint, Paul used AI to 2 The following timeline is a non- exhaustive recitation of counsel’s uses of AI that generated hallucinated cases and quotations. 3 To be clear, this Court’s Order refers to various cases in Florida state court only for background on Paul’s actions.
The Court is not sanctioning Paul for any actions taken in Florida state court. Case 0:25-cv-60630-DSL Document 42 Entered on FLSD Docket 07/17/2025 Page 4 of 21 5 generate at least two hallucinated cases. [Richard Patrick Michael O’Shea v.
CACE-25-003582, on behalf of Debt Dynamics, LLC (“the Debt Dynamics Complaint”). In the Debt Dynamics Complaint, Paul used AI to generate at least two hallucinated cases. [Debt Dynamics, LLC v.
Fla.)]. Paul used AI to generate hallucinated cases and quotations in the Third Federal Case Complaint. [ See id.
1-3]. As a Case 0:25-cv-60630-DSL Document 42 Entered on FLSD Docket 07/17/2025 Page 5 of 21 6 brief example of Paul’s use of hallucinated cases, he cite d “Merrill Lynch v. Hagerty , 808 So.