Washington v. Justice
Pro se appellants filed an initial brief citing eleven nonexistent cases and, after an order to show cause, offered only excuses ("scrivener's errors") and argued the newly amended Fla. R. Gen. Prac. & Jud. Admin. 2.515(d)(2)(D) could not be applied retroactively. The Second District held that no retroactive application was needed because the pre-amendment version of rule 2.515(d)(2), combined with Fla. R. App. P. 9.410(a), already authorized sanctions for signing a filing containing fictitious citations. The court dismissed the appeal and directed the clerk to place in an inactive file any future filings by the appellants related to the underlying circuit court case unless signed by a Florida Bar member.
Key facts
- Pro se appellants filed an initial brief in an appeal citing eleven nonexistent cases, then offered excuses of 'scrivener's errors' when ordered to show cause.
- The appellants argued that any sanctions could not apply because the amended Florida Rule of General Practice and Judicial Administration 2.515(d)(2)(D) could not be applied retroactively to their pre-amendment filing.
- +2 more key facts with a free trial
Why it matters
This decision forecloses the argument—likely to be raised by litigants and counsel caught with AI-hallucinated citations in pre-amendment filings—that sanctions require retroactive application of amended rule… — full analysis with a trial
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