Washington v Justice
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Washington v. Justice concerns a Florida appeal in which a self-represented couple's brief cited eleven nonexistent cases. On October 7, 2026, the Second District Court of Appeal dismissed the appeal under its sanctions authority and restricted future filings related to the underlying action. The court considered generative AI a likely source of the fictitious citations.[1]
Background and citation review
LaVonne and Michael Washington appealed the dismissal of their complaint against Gina Justice and Victor Crist, the latter solely in his official capacity as Hillsborough County Clerk of the Circuit Court and Comptroller. The underlying circuit-court case was No. 24-CA-010301.[1]
After identifying eleven nonexistent cases in the initial brief, the appellate court ordered the Washingtons to provide copies of the cited decisions or explain why sanctions should not be imposed. The opinion describes their response as inadequate. The Washingtons neither admitted nor denied using generative AI; the court found it a likely explanation for the fictitious authorities.[1]
October 7, 2026 disposition
The court relied on Florida Rule of Appellate Procedure 9.410(a), the Washingtons' response to the show-cause order and their pattern of frivolous filings. It explained that pre-existing sanctions authority supported the disposition independently of amendments to rule 2.515 governing accuracy in signed filings.[1]
The opinion's operative reasoning dismisses the appeal. It directs the clerk to place future notices of appeal or original proceedings related to underlying case 24-CA-010301 in an inactive file unless signed by a Florida Bar member in good standing or related to a proceeding already pending when the opinion issued. The directive is limited to the underlying action. The opinion ends with the printed disposition “Affirmed” and is subject to revision before official publication.[1]
Related articles and coverage
- Florida AI Law — Florida AI-law coverage.
- October 8, 2026 digest coverage.
- Cases.