Ulysse v. Vineland Investment Partners Phase II, LLC
A pro se appellant appealing a default judgment in a residential eviction filed an amended initial brief (after his first was stricken) that again contained no citations to the record, in violation of Florida Rule of Appellate Procedure 9.210(b)(3). The Sixth District affirmed because the arguments were insufficiently briefed, and separately ordered the appellant to show cause why he should not be sanctioned after finding that seven cases cited at least twenty times in the brief do not exist.
Key facts
- Pro se appellant appealed a default judgment in a residential eviction case.
- Appellant filed an amended initial brief after his first brief was stricken, but the amended brief again contained no citations to the record in violation of Florida Rule of Appellate Procedure 9.210(b)(3).
- +2 more key facts with a free trial
Why it matters
This is one of a growing line of Florida appellate decisions confronting briefs containing fabricated (apparently AI-generated) case citations, and it identifies a concrete sanction — requiring attorney review and… — full analysis with a trial
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