Sean Ryan v. Alina Perez
The Third District affirmed a final paternity judgment without merits discussion, holding that competent, substantial evidence supported the trial court's child support, income, and evidentiary determinations. The court wrote separately to address the initial brief's reliance on at least ten hallucinated case citations, denied leave to file a corrected brief, and declined to issue an order to show cause only because of the unique circumstances presented. It expressly cautioned that any future failure to verify the accuracy of cited cases will result in sanctions, and emphasized that the problem was aggravated because the self-represented appellant is a member of The Florida Bar.
Key facts
- Sean Ryan appealed a final judgment of paternity entered by the Miami-Dade Circuit Court, challenging the child support and income calculations and certain evidentiary rulings made at the final hearing.
- Ryan represented himself on appeal but is a member of The Florida Bar.
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Holdings
- Self-represented parties — including non-lawyers — are held to the same standard as attorneys in providing accurate citations to the court and are subject to sanctions for submitting…
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Why it matters
This is one of a rapidly growing line of Florida appellate decisions policing AI-generated fake citations, and it is the clearest statement yet that pro se status is no shield — and that Bar membership is an aggravator… — full analysis with a trial
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