Florida Appeals Court Considers Barring Self-Represented Litigant Over 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 AI-generated content in appellate briefs. In the case Gouldy v. Chiasson, the court affirmed the appeal in all respects and issued a separate order to show cause. The court noted that Gouldy's brief contained a nonexistent case, misrepresentations of the record, and fabricated quotations from actual cases. The opinion, written by Judge Robert Gross, highlighted that the use of artificial intelligence to generate briefs is a growing problem in Florida's appellate courts, particularly since the expansion of jurisdiction to include county court appeals. The court emphasized that submitting fictitious case law, whether from carelessness or reliance on generative AI, is sanctionable. Gouldy had previously been warned twice against frivolous filings.