NWFL LLC v. LLC (2026)

ON JOINT STIPULATION FOR DISMISSAL OF APPEAL

Pursuant to the parties’ Joint Stipulation for Dismissal of Appeal docketed April 22, 2026, this appeal is hereby dismissed. Fla. R. App. P. 9.350(c).

However, we expressly retain jurisdiction to pursue any possible sanctions against Steven R. McCommon, Esquire, who, in his Initial Brief, has provided this Court with citations to several cases, some of which appear to be fabricated.

The Initial Brief looks as if it was drafted with the assistance of generative artificial intelligence without Mr. McCommon having put sufficient safeguards in place to ensure the existence or accuracy of the cases cited therein. This is unfortunately not the first time our Court has encountered a filing with citations to cases that do not exist or to cases that are cited for inaccurate legal propositions. See, e.g., Rodriguez v. Rodriguez, No. 6D2025-3086, 2026 WL 969721 (Fla. 6th DCA Apr. 10, 2026).

As we did in Rodriguez, we hereby direct Mr. McCommon to provide copies of each and every case cited in the Initial Brief that actually exists, with highlighted quotations or language that support the assertions made in the Initial Brief. These cases shall be filed with this Court within ten days of the issuance of this Order. Additionally, Mr. McCommon is directed to show cause within ten days of the issuance of this Order: (1) why he should not be sanctioned for filing an initial brief that contains non-existent cases and that cites to cases for inaccurate legal propositions; and (2) why he should not be referred to The Florida Bar for potential discipline.

DISMISSED. ORDER TO SHOW CAUSE ISSUED.

NARDELLA, WOZNIAK and GANNAM, JJ., concur.