Florida Supreme Court Requires Lawyers to Certify AI-Generated Citations Are Accurate
Effective June 15, 2026, Florida lawyers must certify that every legal authority cited in court filings actually exists and is accurately quoted. The Florida Supreme Court amended Rule 2.515(d)(2) to address a growing problem: generative AI systems that fabricate case citations and produce plausible-sounding but false legal authorities.
The rule applies to all signers of court documents, including self-represented litigants. It requires a straightforward representation: "the legal authorities identified exist and are accurately cited."
What Prompted the Change
Federal and state courts have repeatedly encountered briefs containing cases that do not exist, citations that do not support their stated propositions, and legal analyses generated by AI without adequate attorney review. Judges have issued sanctions against lawyers who submitted filings with AI-generated errors, reinforcing that attorneys-not software-remain responsible for accuracy.
The Florida Supreme Court said generative AI systems "can generate content that appears plausible but is in fact inaccurate, including fabricated or 'hallucinated' authorities." Rather than letting individual circuit courts impose their own requirements, the state chose a uniform statewide standard.
New Sanctions Authority
Courts can now impose sanctions when a filing contradicts the signer's certification. Available penalties include reprimand, contempt, striking the document, dismissal of proceedings, costs, attorneys' fees, or other appropriate sanctions. The court must provide notice and an opportunity to be heard before imposing sanctions.
While courts already possessed various sanctioning powers, the Florida Supreme Court clarified its authority specifically to address inaccurate AI-assisted filings.
What the Rule Does Not Do
The amendment does not ban AI use. It does not require lawyers to disclose every instance in which AI assisted with drafting or research. Instead, it reinforces a professional obligation that predates artificial intelligence: independent verification of all legal authorities before filing.
Practical Steps for Attorneys
Lawyers should implement safeguards to prevent AI hallucinations from reaching the court:
- Independently review every citation generated by AI tools.
- Confirm that all cited authorities actually exist.
- Read the underlying cases rather than relying on AI-generated summaries.
- Verify quotations, pinpoint citations, and procedural histories.
- Establish firm policies governing AI-assisted drafting and legal research.
- Train lawyers and staff regarding the risks of AI hallucinations.
The core principle is straightforward: AI may assist in drafting, but it cannot replace the attorney's obligation to ensure accuracy before filing.
A Model for Other States
Florida's approach may influence how other jurisdictions address AI in court filings. Courts across the country have struggled with how to balance technological innovation against judicial integrity. Florida chose a statewide certification requirement rather than a patchwork of local orders.
For legal professionals using AI for Legal work, understanding these verification requirements is essential. Paralegals involved in document preparation should review resources on AI Learning Path for Paralegals to understand how to identify and prevent citation errors before documents reach attorneys for final review.
Your membership also unlocks:
