A federal court in Jacksonville has closed its inquiry into fake citations in a filing that included AI-assisted research, finding counsel's remediation a suitable remedy

Key takeaways

• The court found at least two fake citations in a memorandum of law: one non-existent case and one that did not include the quotation attributed to it.
• Counsel told the court he failed to properly review a document that included materials generated by research conducted using AI.
• The court found the steps counsel had already taken a suitable remedy, took no further action, and left the file closed.
• The order is tied to "the circumstances of this case" and sets no requirement for other lawyers.

What did the court find, and how did it resolve the inquiry?

The court found, in its words, that counsel's memorandum of law "contained at least two fake citations (one case was non-existent; another did not include the quotation attributed to it)". It discovered this when counsel for the plaintiff filed two notices of errata to correct errors in the memorandum.

The case then settled, but the court scheduled a hearing "to further investigate". The hearing took place on October 1, 2026. After it, the court wrote that it was "satisfied that counsel understands the gravity of his actions and will not repeat them", that the measures already undertaken are "a suitable remedy" in the circumstances of the case, and that "no further action will be necessary. This file remains closed."

What had counsel already done before the hearing?

The order says that at the hearing counsel explained how, in his haste to meet a filing deadline, he failed to properly review the document, which included materials generated by research conducted using AI. The order records this as his explanation; it does not itself find that haste caused the error. It describes him as candid about his carelessness. The order does not say which AI tool was used.

It lists the steps taken since the error was uncovered and before the hearing: he told and apologized to his client; he told and apologized to opposing counsel, who advised that they had not been prejudiced; he gave the entirety of his fee, an amount approximating $10,000, to Jacksonville Area Legal Aid; he attended 7.5 hours of CLE courses on AI ethics; and he described a number of changes to his office procedures. At the hearing he also apologized to the court.

What did the court say about lawyers' duties when using AI?

The court quoted its own earlier opinion in Hodges v. Meridian Waste Acquisitions, LLC, No. 3:25-cv-62-TJC-SJH (Doc. 53 at 2) (M.D. Fla. Jan. 16, 2026). In the passage the order reproduces, the court says lawyers are ethically bound in all court filings to provide true and accurate record and case citations, and that use of AI as a legal research tool does not alter the requirement of candor to the tribunal.

The passage ends: "It is not acceptable conduct; it will not be tolerated." It is directed at relying on AI or the assistance of others without verification. We did not open the Hodges opinion itself; this account relies on the extract in the Glenn order.

What should litigators and firm managers take from it?

The order states what counsel did and that the court found it suitable in this case. It does not set a list of steps that a court would require, and it does not say a different set of facts would end the same way. In our reading, the useful point is documentary: the court recorded specific, verifiable steps, and it listed them one by one.

For litigators, supervising lawyers and firm managers who approve AI-assisted research, the practical questions that follow from the order are these:

• Who verifies every record and case citation, and quotation, before a filing goes out, and is that step recorded?
• Does a filing deadline change that review step? Counsel told the court the error came from haste to meet a filing deadline; the order records that explanation.
• If an error is found after filing, who tells the client, opposing counsel and the court, and how quickly? The order notes that counsel filed two notices of errata.
• Which written office procedures cover AI-assisted research? The order says counsel described changes to his office procedures but does not set them out.

What are the key dates and parties?

What we did not verify

What we opened: the three-page order (Doc. 74, filed 10/09/26), as a PDF copy stored in the CourtListener RECAP archive, on 2026-10-25.

What we did not open: the PACER docket or the court's own website, the transcript of the 1 October 2026 hearing (the order incorporates it by reference), the memorandum of law and the two notices of errata, the Hodges v. Meridian Waste Acquisitions opinion, and any later filing in the case. The order does not name counsel or the two cases cited, and we have not tried to identify them.

What we refuse to claim: that the court imposed or declined any sanction beyond what the order says, that the listed steps are required of other lawyers, which AI tool was used, or how other courts would treat similar facts.

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