US | United States District Court for the Middle District of Florida
Docket: 2:25-cv-838-SPC-NPM • first instance
2025-11-26
The Doc App, Inc. v. Leafwell, Inc. — opinion and order (rule 11 sanctions)
Unknown / Not Disclosed fake case citationfake quotationno meaningful verificationsuspected generative ai use
I. Executive Summary
The court found that counsel filed a TRO motion containing fabricated cases, quotations not found in cited decisions, and authorities unrelated to the propositions asserted. The opposing party argued the filings bore hallmarks of AI drafting, and the court noted counsel did not directly address any AI use. The court imposed Rule 11 sanctions, including fee shifting, an AI ethics CLE requirement, client notice measures, and a referral to the Florida Bar.
II. Conduct Analysis
Counsel filed emergency injunctive-relief papers containing fabricated and misleading citations and quotations; the record reflects allegations that the filings bore hallmarks of AI-generated work product, while counsel did not disclose the tool used or confirm whether AI was used.
III. Legal Foundations
Fed. R. Civ. P. 11(b)
Fed. R. Civ. P. 11(c)
Fed. R. Civ. P. 11(c)(5)(B)
M.D. Fla. Local Rule 7.01(c) (fee application timing)
IV. Key Facts
1) The TRO motion included fabricated cases, quotations not present in cited authorities, and citations unrelated to the stated propositions.
2) The court issued an order to show cause and later concluded counsel violated Rule 11(b) in filing the motion.
3) The court noted the opposing party’s contention that the filings bore hallmarks of AI-generated drafting and that counsel remained silent about AI use.
V. Consequences & Sanction
1) Counsel was ordered to pay the defendant’s attorneys’ fees and costs caused by responding to the TRO motion.
2) The court imposed practice-restriction style safeguards (attachment of the sanctions order in future filings) and required AI ethics CLE.
3) The court required notice to the client’s CEO and referred counsel to the Florida Bar.