Florida Appeals Court Considers Barring Self-Represented Litigant for AI-Fabricated Citations
The Florida Court of Appeal has ordered litigant Gouldy to show cause why she should not be barred from further self-represented filings, citing her use of fabricated citations and fake quotes generated by artificial intelligence. In the case Gouldy v. Chiasson, the court affirmed the underlying appeal as frivolous, noting that Gouldy's brief contained a nonexistent case, misrepresentations of the record, and fabricated quotations from actual legal decisions. The court highlighted a growing problem in Florida's appellate courts, where pro se litigants increasingly use AI platforms to generate briefs that include 'phantom authority' and misstatements. Gouldy had been warned twice previously about frivolous filings. The court referenced recent precedents allowing sanctions for reliance on phantom authority, and stated that such conduct meets the standard for bad-faith filings under Florida appellate rules.
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