Published opinion, 23 September 2026 · source · PDF · 4 pages
We conclude that the arguments presented lack merit and that competent, substantial evidence supports the trial court’s determinations.1 We therefore affirm without further discussion on the merits. But we write to address the fact that the initial brief relied extensively on hallucinated case cites ( to either nonexistent cases or cases that are miscited and, in any event, do not support the legal proposition for which they are proffered). The answer brief details no fewer than ten hallucinated cases.
3d 1185, 1188 (Fla. 3d DCA 2024) (“ We find Gutierrez ’s failure to comply with rule 9.210(b) and submission of fictitious case law to this court sufficient to 1 See Garnett v. Duvalsaint , 400 So.
The problem here is exacerbated by the fact that the self-represented appellant is a member of the Florida Bar. The “proliferation of fake or hallucinated case citations in court filings ” is “an issue of growing concern,” and “[w]e aren’t the only court in Florida [or elsewhere] to address this problem.” Takefman v. Pickleball Club, LLC, 418 So.
2 Ryan’s motion seeking leave to file a corrected initial brief attempts to explain the errors that resulted in filing the initial brief with hallucinated citations.