Mathews v. Ketchum does not exist — a fabricated AI citation

In Edwards v. De Cubas & Lewis, P.A., the plaintiffs' filing cited “Mathews v. Ketchum, 41 So. 3d 243 (Fla. 2d DCA 2010)” as authority. The U.S. District Court for the Middle District of Florida could not locate any such Second District Court of Appeal decision at that citation and deemed it nonexistent.

This was not an isolated fabrication in the filing — the same brief also cited a second invented Florida appellate case, Gharbi v. Williams, 919 So. 2d 595 (Fla. 5th DCA 2006), which the court likewise could not find and likewise deemed nonexistent. Two separate fake Florida DCA citations, from two different district courts of appeal, in the same document, suggests a research process that generated supporting authority wholesale rather than one isolated slip.

Both fabricated cases carry the exact formatting convention (So. 3d or So. 2d reporter, specific DCA district, plausible year) that real Florida appellate citations use, which is precisely why neither one would raise suspicion on a skim — only an actual database lookup against the Southern Reporter surfaces that they are not there. Florida's five-district Court of Appeal structure, each with its own reporter conventions, makes this kind of fabrication especially hard to eyeball: a citation to the wrong DCA, or to a plausible-but-fake volume number, reads as entirely normal to anyone who doesn't already know that particular district's reporter by heart. Both fake citations in this filing were caught at the warning stage rather than after a dispositive ruling relied on them — a reminder that opposing counsel and the court itself remain the last real check when a filer's own verification step is skipped.