ROBERT HINTON AVERY
v.
DANIELLE BEAUZIL

Fla. 4th DCA | 2026-05-20
No. 2025-2116
Marra, J., Gross, J., Levine, J., Forst, J.
2026 FL 6027 Florida District Court of Appeal, Fourth District (2026)

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Holding

Reliance on phantom authority in legal proceedings is sanctionable conduct.


Headnotes

[1] Reliance on phantom authority—non-existent or fabricated legal citations—in legal proceedings constitutes sanctionable conduct.

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Key Quotes

“reliance on 'phantom authority' is sanctionable”

The court cited Friend v. Serpa for the proposition that reliance on phantom authority is sanctionable conduct.

Facts & Procedural History

Robert Hinton Avery appealed a judgment from the Circuit Court for the Seventeenth Judicial Circuit in Broward County in a domestic relations case.…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

ROBERT HINTON AVERY, Appellant,

V.

DANIELLE BEAUZIL, Appellee.

No. 4D2025-2116

[May 20, 2026]

Appeal from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Jessica Marra, Judge; L.T. Case No. 062024DR016490AXDVCE.

Robert Hinton Avery, Pembroke Pines, pro se.

No appearance for appellee.

PER CURIAM.

Affirmed. See Friend v. Serpa, 425 So. 3d 51, 51 (Fla. 4th DCA 2025) (explaining that reliance on “phantom authority" is sanctionable); Goya v. Hayashida, 418 So. 3d 652, 656 (Fla. 4th DCA 2025).

GROSS, LEVINE and FORST, JJ., concur.

* * *

Not final until disposition of timely-filed motion for rehearing.


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