GLEASON
v.
MARCUS, CANVASSING BOARD OF PINELLAS COUNTY
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The dismissal of the complaint is affirmed, and litigants must ensure the accuracy of their filings or risk sanctions for relying on generative artificial intelligence that produces fabricated citations.
[1] Blind reliance on generative artificial intelligence to prepare legal briefs containing fabricated case citations and misquoted legal propositions is unwise, unacceptable…
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Join FLexlaw to unlock all legal intelligence“This technology is very good at sounding right, but less adept at being right, and blind reliance on it is unwise, unacceptable, and sanctionable.”
Court's warning about the dangers of using generative artificial intelligence in legal briefs
Christopher Gleason appealed a circuit court order dismissing his complaint with prejudice. His appellate briefs cited numerous nonexistent cases and …
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DISTRICT COURT OF APPEAL OF FLORIDA
SECOND DISTRICT
CHRISTOPHER GLEASON,
Appellant,
v.
JULIE MARCUS, in her official capacity as Pinellas County Supervisor of Elections,
Appellee.
No. 2D2024-2688
May 13, 2026
Appeal from the Circuit Court for Pinellas County; Patricia A. Muscarella, Judge.
Christopher Gleason, pro se.
Jared D. Kahn, Senior Assistant County Attorney, Clearwater, for Appellee.
PER CURIAM.
Christopher Gleason seeks review of a final order dismissing his complaint with prejudice. We conclude that his arguments lack merit, and we affirm the order without further comment on the issues raised. But we are compelled to comment on Mr. Gleason's apparent use of artificial intelligence to prepare the briefs he filed with this court. His briefs cite numerous cases that do not exist, and they frequently quote case law for propositions that appear nowhere in the cases cited.
We have cautioned on the dangers of using generative artificial intelligence before, see, e.g., Russell v. Mells, 426 So. 3d 913, 920 (Fla. 2d DCA 2025), and we again sound the alarm. "This technology is very good at sounding right, but less adept at being right," and "blind reliance" on it is unwise, unacceptable, and sanctionable. See Gouveia v. Meridian Fin. Invs., LLC, No. 4D2025-0843, 2026 WL 816497, at *3 (Fla. 4th DCA Mar. 25, 2026) (Lott, J., concurring); see also Gutierrez v. Gutierrez, 399 So. 3d 1185, 1187–88 (Fla. 3d DCA 2024) (sanctioning pro se litigant for citing multiple nonexistent cases in his appellate briefs).
We notify Mr. Gleason that future filings of this nature will not receive favorable treatment, and we remind all litigants—both pro se and represented—that they must ensure the accuracy of their filings or risk the consequences. See Fla. R. App. P. 9.045(d); Fla. R. Jud. Admin. 2.515(d)(2); Francois v. Vive Fin., LLC, No. 4D2025-2088, 2026 WL 758289, at *1 (Fla. 4th DCA Mar. 18, 2026); Goya v. Hayashida, 418 So. 3d 652, 655 (Fla. 4th DCA 2025); cf. Hessert v. Hessert, No. 6D2026- 0121, 2026 WL 785016, at *2 (Fla. 6th DCA Mar. 20, 2026) ("If and when any such erroneous filings [containing nonexistent cases or inaccurate legal propositions] are made . . . , filers on the opposite side of the case should point out such errors . . . in their responsive filings or via motion."); Noland v. Land of the Free, L.P., 336 Cal. Rptr. 3d 897, 915 (Cal. Ct. App. 2025) (denying sanctions payable to opponents who "did not alert the court to the fabricated citations" and awarding sanctions payable to the court instead).
KELLY, ROTHSTEIN-YOUAKIM, and LABRIT, JJ., Concur.
Opinion subject to revision prior to official publication.
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Cap. Standard, LLC v. US Bank Nat'l Ass'n (Fla. 2d DCA 2026)
Authorities Cited
- Hessert v. Hessert, 2026 WL 785016 (Fla. 6th DCA 2026)
- Russell v. Mells, 426 So. 3d 913 (Fla. 2d DCA 2025)
- Elilton Alves Gouveia v. Meridian Fin. Invs., LLC, 2026 WL 816497 (Fla. 4th DCA 2026)