Sanction teardown · Fla. 2d DCA, USA · 2026-08-21

Capital Standard, LLC v. U.S. Bank National Association

What happened

In Fla. 2d DCA, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

• Misrepresented (Case Law)
  Cited Maciejewski v. Holland, 441 So. 2d 703 (Fla. 2d DCA 1983) for unrelated propositions (e.g., ratification), though the two-page opinion does not contain those propositions.
• False Quotes (Case Law)
  Attributed a nonexistent quotation about 'fundamental error' to Hart Properties, Inc. v. Slack and provided a pincite that does not contain the quote.
• Misrepresented (Case Law)
  Used Miami Country Day School v. Bakst, 641 So. 2d 467 (Fla. 3d DCA 1994) (a homestead/houseboat case) to support broad propositions about good-faith acquisition and detrimental reliance not found in that opinion.
• Fabricated (Case Law)
  Presented Board of Regents v. Wilson, 365 So. 2d 213 (Fla. 1st DCA 1979) as authority though the court identified it as a fabricated/nonexistent case.
• Misrepresented (Case Law)
  Cited Gonzalez v. Deutsche Bank Nat'l Tr. Co., 95 So. 3d 251 (Fla. 2d DCA 2012) as an all-purpose authority for matters (e.g., bona fide purchaser principles) that the opinion does not address.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Attorney Keefe fined $1,500; ordered to pay U.S. Bank's appellate fees for researching and answering the amended initial brief (amount remanded to trial court); referred to The Florida Bar; offending briefs struck. (monetary penalty: 1 .)

Additional detail

Attorney Kenneth Keefe relied on a generative AI tool that produced numerous AI "hallucinations" (fabricated cases, false quotations, and misstatements of existing authorities) across his amended initial brief and reply. The court issued a show-cause, found at least 46 specific hallucinations, ordered Keefe to produce supporting authorities, received no timely compliance, struck the offending briefs, and imposed sanctions: a $1,500 fine, an award of fees to U.S. Bank for researching and answering the amended brief (amount remanded for determination), and referral to The Florida Bar. The court based sanctions on violations of Fla. R. Gen. Prac. & Jud. Admin. 2.515(d) and Fla. R. App. P. 9.210/9.410(a), noting the burden on courts and opposing parties and the duty of counsel to verify authorities.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/2906/Capital_Standard_v._US_Bank_NA_USA_21_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).