Kid International LLC v City National Bank of Florida
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Kid International, LLC v. City National Bank of Florida is a Florida appellate decision concerning sanctions for fabricated authorities and quotations in an AI-assisted brief. On October 7, 2026, the Fourth District Court of Appeal affirmed a summary judgment and granted the defendants' motion for sanctions. It awarded reasonable appellate attorney's fees, with the plaintiffs and their counsel jointly and severally liable, and remanded for the circuit court to determine the amount.[1]
Background
Kid International, LLC, Lichi, LLC and Yaron Katz appealed a final summary judgment for City National Bank of Florida and 2655 SW 25, LLC. The appellate court concluded that the plaintiffs' claims were barred by the statute of limitations and affirmed without further discussion of the merits.[1]
AI-assisted briefing and verification
The defendants sought sanctions over fabricated case law, fictional quotations and misstated holdings. The court's independent review identified a nonexistent case cited seven times, incorrect descriptions of a federal bank case and other inaccurate authorities and quotations. Its sanctions analysis focused on the appellate initial brief.[1]
Counsel accepted responsibility for inadequate verification. He explained that he had accepted research assistance from a client and that his firm used generative AI as part of its research and drafting process. An attempted amended brief did not resolve all citation issues. Counsel represented that he had changed his procedures to require independent checks against authoritative legal sources.[1]
The court proceeded with the initial brief while disregarding the hallucinated citations, quotations and misstated holdings.[1]
October 7, 2026 ruling and status
The court extended the reasoning of prior fictitious-citation sanctions decisions to a party's motion for attorney's fees under Florida Rule of Appellate Procedure 9.410(b). It granted the motion and awarded the defendants their reasonable attorney's fees for litigating the appeal. The circuit court must determine the amount on remand. The plaintiffs and their counsel are jointly and severally liable; qualifying rehearing-related services may be included in the calculation.[1]
The opinion states that it is not final until disposition of a timely-filed motion for rehearing.[1]