SAMANTHA ROUSSELL
v.
THE BANK OF NEW YORK MELLON, ETC., ET AL.
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
The Florida District Court of Appeal affirmed the lower court's decision on the merits but expressed serious concerns about the appellant's brief, which contained thirteen non-existent case citations and nine misrepresented existing cases, likely generated by artificial intelligence without adequate verification.
The lower court's decision is affirmed on the merits. The court declines to impose sanctions but warns that parties using artificial intelligence in brief preparation must ensure accuracy and may face sanctions under Florida Rule of Appellate Procedure 9.410(a) for failure to comply with Rule 9.210(c).
[1] A party is responsible for the accuracy of all content submitted to the court, regardless of whether they are represented by counsel or proceeding pro se.
[2] A court may sanction a party for failing to comply with rules governing the content and accuracy of appellate briefs.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The appellant cited thirteen different cases that do not exist. We expressly disregard these hallucinated cases.”
Establishes that the court identified and rejected fabricated case citations in the brief.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceThe appellant submitted a brief containing multiple deficient citations: thirteen cases that do not exist and nine existing cases cited for propositio…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT
SAMANTHA ROUSSELL, Appellant,
V.
THE BANK OF NEW YORK MELLON, ETC., et al., Appellees.
No. 4D2025-1309
[March 11, 2026]
Appeal from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Gary Michael Farmer, Jr., Judge; L.T. Case No. CACE17006417.
Samantha Roussell, Miramar, pro se.
Alec P. Hayes of Troutman Pepper Locke LLP, Atlanta, GA, for appellee The Bank of New York Mellon.
No appearance for appellee Sunset Lakes Master Assn., Inc. PER CURIAM.
After careful consideration of the parties' briefs and the record, we affirm on the merits without discussion. We write, however, to address our concerns with the purported legal authority upon which the appellant relied in her brief. The appellant cited thirteen different cases that do not exist. We expressly disregard these hallucinated cases. Furthermore, the appellant cited nine different cases that do exist, but do not stand for the proposition described by the appellant. A party, whether represented by counsel or proceeding pro se, is responsible for the content of any submission to the court. If a party chooses to use artificial intelligence to assist in the preparation of a brief, it must do so with care and take steps to ensure the accuracy of any submissions to the court. “While we decline to do so here, this court has the authority to sanction appellant under Florida Rule of Appellate Procedure 9.410(a) for failure to comply with Florida Rule of Appellate Procedure 9.210(c).” Friend v. Serpa, 425 So. 3d 51 (Fla. 4th DCA 2025) (citing Goya v. Hayashida, 418 So. 3d 652, 656 (Fla. 4th DCA 2025)).
Affirmed.
LEVINE, CONNER and SHAW, JJ., concur. * * *
Not final until disposition of timely-filed motion for rehearing.