Prousalis v. Bert's Bikes & Fitness does not exist — a fabricated AI citation

In Julia Rose v. Arts Bonita, Inc., et al., the plaintiff cited a decision styled “Prousalis v. Bert's Bikes & Fitness, No. 8:18-cv-1234, 2019 WL 13202785 (M.D. Fla. 2019).” The U.S. District Court for the Middle District of Florida identified this citation as fabricated.

The distinctive, slightly whimsical defendant name — “Bert's Bikes & Fitness” — is worth noting on its own: unlike the airline, bank, and municipal defendants that dominate this database, a small-business-sounding party name reads as more, not less, credible on a skim, precisely because it doesn't carry the institutional weight that might prompt extra scrutiny. A specific docket number (8:18-cv-1234) and a full Westlaw identifier round out a citation built to survive a glance rather than a lookup.

As with most single-fabrication entries in this database, the court's finding functioned as a formal warning rather than an immediate monetary penalty — the documented consequence here is the sanctions record itself, now searchable and public, which is precisely the deterrent this project exists to reinforce: every fabricated citation that gets caught and published makes the next one riskier to try. Cases like this one, filed by a plaintiff rather than a large firm's associate, are a reminder that AI-citation risk is not confined to overworked biglaw practice — it shows up just as often in smaller, single-plaintiff federal litigation where no one else on the filing team is positioned to catch it.