An Eleventh Circuit panel affirmed dismissal of a challenge to pandemic workplace rules and sharply criticized the plaintiffs lead lawyer for relying on artificial intelligence that produced fake case citations. The court said Sabatini filed multiple briefs filled with hallucinated authorities and that by outsourcing his legal research and drafting to an AI he violated ethical duties to his clients and to the court. The opinion also noted that the list of withdrawn citations did not match the false authorities in the opening brief and that the substituted authorities were also fabricated.
The Eleventh Circuit affirmed the dismissal of a challenge to employer pandemic policies and issued a strong critique of the plaintiffs counsel for his use of artificial intelligence in preparing appellate filings. Sabatini filed multiple briefs replete with fake and hallucinated citations. By outsourcing his legal work to an AI algorithm, Sabatini violated his ethical duties to both his clients and this Court. The opinion explained that the opening brief relied on several nonexistent authorities, and that after defendants identified the problem the attorney conceded the cited authorities were erroneous or unverifiable. The court further observed that the set of citations the attorney later attempted to withdraw did not correspond to the false authorities in the opening brief and that those substitute citations were likewise fabricated. The opinion framed these problems as part of why the panel found the pleaded claims insufficient and affirmed dismissal for lack of personal jurisdiction and for failure to state a claim.
Key Points #
- 1An appellate panel affirmed dismissal of the suit for lack of personal jurisdiction and failure to state a claim.
- 2The opinion found counsel presented briefs with fabricated case citations after relying on an artificial intelligence tool for research and drafting.
- 3The court concluded the attorney violated ethical obligations to clients and the court by outsourcing legal work to an AI algorithm.
Scoring Rationale #
The decision formalizes a public judicial reprimand over AI produced fabrications and highlights heightened judicial scrutiny of AI assisted legal research and citation accuracy.
Sources #
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