Christopher Gleason v. Julie Marcus, in her official capacity as Pinellas County Supervisor of Elections
The Second DCA affirmed the dismissal of Gleason's complaint without comment on the merits but issued a published warning about his apparent use of generative AI to prepare briefs containing fabricated case citations and misquoted holdings. The court cautioned that blind reliance on such technology is 'unwise, unacceptable, and sanctionable' and warned that future filings of that nature would not receive favorable treatment.
Key facts
- Christopher Gleason, appearing pro se, sued Julie Marcus in her official capacity as Pinellas County Supervisor of Elections; the trial court dismissed his complaint with prejudice.
- On appeal, Gleason's briefs cited numerous nonexistent cases and quoted holdings that appeared nowhere in the cited authorities, apparently generated by artificial intelligence.
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Holdings
- Litigants — pro se and represented alike — must ensure the accuracy of their filings; blind reliance on generative AI that produces nonexistent citations and fabricated quotations is…
Why it matters
Part of a fast-growing line of Florida appellate decisions confronting AI-fabricated legal authority, this opinion puts all litigants on notice that submitting briefs with hallucinated citations risks sanctions and… — full analysis with a trial
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