Docket entry 68, 12 August 2026 · source · PDF · 4 pages
Docket text. ORDER granting in part and denying in part 48 Defendant Arts Bonita, Inc.'s Motion for Entry of Order on Generative AI Use. Plaintiff is WARNED any future citation to nonexistent authority, a misquotation of existing authority, or a misrepresentation of the record may result in sanctions, as stated in the Order. Signed by Magistrate Judge Kevin R. Huguelet on 8/12/2026. (TMA)
2019). That case does not exist. 2 Once Arts Bonita caught the error, it asked Rose to join an agreed order on generative AI use.
31, 2026). Rose’s conduct falls near the bottom of that range—i.e., a single hallucinated citation. Even so, a fabricated citation is never harmless since it forces the opposing party and the Court to “waste time and money in exposing the deception.” O’Brien, 2025 WL 242924, at *6 (quoting Mata v.
That said, the Court does not read th e withdrawal as the end of the matter. Rose did not catch the error herself, and her assurance that she will personally verify her own filings going forward is the same assurance she gave before the fabricated citation surfac ed. A sanction is not yet warranted, but the record supports an admonishment.
To the extent Arts Bonita seeks a warning to Plaintiff regarding the accuracy of her filings, the Motion is GRANTED. Plaintiff is WARNED any future citation to nonexistent authority, a misquotation of existing authority, or a patent misrepresentation of the record—w hether her own work or produced with the assistance of generative artificial intelligence—may result in a sanction under Federal Rule of Civil Procedure 11. In Fort Myers, Florida on August 12th, 2026.