Artificial intelligence has quickly become part of the modern lawyer’s toolkit. Attorneys are using generative AI platforms to assist with legal research, drafting, editing, and document review. While these technologies can improve efficiency, a growing number of court filings across the country demonstrate a significant risk: AI-generated hallucinations, including fabricated case citations, nonexistent authorities, and inaccurate quotations.
Recent sanctions decisions from federal and state courts have highlighted the problem. Judges have encountered briefs containing cases that do not exist, citations that do not support the propositions for which they are offered, and legal analyses generated by AI systems without adequate attorney verification. These incidents have reinforced a fundamental principle of legal practice: lawyers—not software—remain responsible for the accuracy of every filing submitted to a court.
Recognizing these concerns, the Florida Supreme Court has amended Florida Rule of General Practice and Judicial Administration 2.515 to establish a clear statewide standard governing representations made when documents are filed in Florida courts.
Florida’s New Rule
Effective June 15, 2026, Rule 2.515(d)(2) requires every signer of a court filing to represent that:
The amendment applies not only to attorneys but also to self-represented litigants.
The Court’s action reflects growing concern about the use of generative AI tools that may produce authoritative-sounding but inaccurate information. In its per curiam opinion, the Court expressly noted that generative AI systems “can generate content that appears plausible but is in fact inaccurate, including fabricated or ‘hallucinated’ authorities.”
A Statewide Response to a Growing Problem
Rather than adopting a patchwork of local requirements, the Florida Supreme Court chose a statewide approach. According to the Court’s commentary, the amendments were adopted
“principally to create a statewide, uniform replacement for varied circuit court administrative orders imposing disclosure and certification requirements about the use of artificial intelligence in filings.”
New Sanctions Authority
The amended rule also expressly authorizes courts to impose sanctions when a filing is inconsistent with the signer’s certification. The rule provides that sanctions may be imposed after notice and an opportunity to be heard and may include:
- Reprimand;
- Contempt;
- Striking the document;
- Dismissal of proceedings;
- Costs;
- Attorneys’ fees; or
- Other appropriate sanctions.
Although courts already possessed various sanctioning powers, the Florida Supreme Court made clear that the new provision is intended to eliminate uncertainty regarding courts’ authority to address inaccurate filings in the AI context.
What This Means for Lawyers
The amendment does not prohibit the use of AI. Nor does it require attorneys to disclose every instance in which AI assisted with drafting or research. Instead, it reinforces a basic professional obligation that predates artificial intelligence: lawyers must independently verify the accuracy of the legal authorities cited in their filings.
As generative AI becomes more sophisticated and more widely used, attorneys should consider implementing safeguards such as:
- Independently reviewing every citation generated by AI tools.
- Reading the underlying cases rather than relying on AI-generated summaries.
- Verifying quotations, pinpoint citations, and procedural histories.
- Establishing firm policies governing AI-assisted drafting and legal research.
- Training lawyers and staff regarding the risks of AI hallucinations and citation errors.
The Continuing Duty of Professional Judgment
The Florida Supreme Court’s amendment serves as a reminder that technological innovation does not alter a lawyer’s fundamental duties of competence, diligence, and candor to the tribunal. AI may assist in the drafting process, but it cannot replace the attorney’s obligation to ensure that every legal authority presented to a court is real, accurate, and properly cited.