RYAN v. PEREZ (2026)

Sean Ryan seeks review of a final judgment of paternity, specifically relating to child support and income calculations, as well as evidentiary rulings made by the trial court at the final hearing. We conclude that the arguments presented lack merit and that competent, substantial evidence supports the trial court's determinations.¹ We therefore affirm without further discussion on the merits.

But we write to address the fact that the initial brief relied extensively on hallucinated case cites (to either nonexistent cases or cases that are miscited and, in any event, do not support the legal proposition for which they are proffered). The answer brief details no fewer than ten hallucinated cases. We have explained that even non-lawyer, self-represented parties are subject to sanctions and held to the same standards as a lawyer in providing accurate citations to the court. See Gutierrez v. Gutierrez, 399 So. 3d 1185, 1188 (Fla. 3d DCA 2024) (“We find Gutierrez's failure to comply with rule 9.210(b) and submission of fictitious case law to this court sufficient to warrant the imposition of sanctions.”). The problem here is exacerbated by the fact that the self-represented appellant is a member of the Florida Bar.

The “proliferation of fake or hallucinated case citations in court filings” is “an issue of growing concern,” and “[w]e aren't the only court in Florida [or elsewhere] to address this problem.” Takefman v. Pickleball Club, LLC, 418 So. 3d 826, 826 (Fla. 3d DCA 2025); see also Hessert v. Hessert, 431 So. 3d 610, 613 (Fla. 6th DCA 2026) (collecting cases involving improper use of AI). Our sister court explained that “[a]n attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” Goya v. Hayashida, 418 So. 3d 652, 655 (Fla. 4th DCA 2025) (quotation omitted). And here, the answer brief accurately detailed the numerous hallucinations and explained how these errors went to the core of many of the legal arguments presented.²

Ryan's motion seeking leave to file a corrected initial brief attempts to explain the errors that resulted in filing the initial brief with hallucinated citations. We note, however, that the motion does not explain why it took the filing of the answer brief for Ryan to realize that he filed a brief with ten hallucinated citations. Nor does it explain why Ryan failed to attach the purported corrected initial brief which he claimed he had available, and which he claimed contained accurate citations supporting “[e]ach legal proposition advanced in the Initial Brief.” Nonetheless, we decline to issue an order to show cause based on the unique circumstances of this case. We caution Ryan, however, that any future failure to verify the accuracy of cases cited in a filing before this court will result in sanctions.

Affirmed.

FOOTNOTES

1.   See Garnett v. Duvalsaint, 400 So. 3d 682, 683 (Fla. 3d DCA 2024) (explaining standard of review); see also Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150, 1152 (Fla. 1979) (“Without a record of the trial proceedings, the appellate court can not properly resolve the underlying factual issues so as to conclude that the trial court's judgment is not supported by the evidence or by an alternative theory.”).

2.   We deny Ryan's motion for leave to file an initial brief “with correct citations.” Not only does the motion (filed after the answer was filed) not attach the proposed corrected initial brief referenced in the motion, but there is no reason given that supports Ryan receiving a “do over” and forcing the appellee, and this court, to re-brief the matter.

PER CURIAM.