Florida Rule 2.515: The New AI Citation Certification Effective June 15
On June 15, 2026, a new representation attaches to every document filed in a Florida state court. The Florida Supreme Court amended Rule of General Practice and Judicial Administration 2.515 so that the person who signs a filing represents that the legal authorities identified in the document exist and are accurately cited. The standard is short. It is also statewide, and it reaches every signer, not only members of the Bar.
The amendment is the court's answer to a problem that has arrived on Florida dockets the same way it has arrived elsewhere. A brief is drafted with the assistance of a generative tool. A citation in the brief points to an opinion that cannot be located in the reporter it names. The filing is signed before anyone confirms that the authority exists. Rule 2.515 now names the representation that the signature carries.
What the amended rule says
The Florida Supreme Court adopted the amendment in In re Amendments to Florida Rule of General Practice and Judicial Administration 2.515, No. SC2026-0673. The operative language adds to the existing signing rule a representation that the legal authorities identified in the filing "exist and are accurately cited." The representation runs to the signer of the document. It applies to attorneys and to self-represented parties on the same terms.
The court was explicit about what the amendment does not do. It does not prohibit the use of artificial intelligence. It does not require a lawyer to disclose every instance in which a tool assisted with drafting or research. The rule attaches to the citations in the filing, not to the tools that produced the draft. A filer may use any tool. The filer represents that the authorities the filing relies on are real and are cited correctly.
The court adopted the amendment to create a uniform, statewide standard in place of the patchwork of individual orders that Florida trial judges had begun entering on AI use in filings. One rule now governs the representation across the state court system. A firm that appears before more than one Florida court no longer reads a different standing order in each division to learn what it has certified.
What the representation actually asks
The representation has two parts, and they are different obligations. The first is existence. The authority cited has to be a real opinion that can be located in the reporter and at the page the filing names. The second is accuracy. The citation has to point to the authority it claims to point to, cited correctly. A real case cited to the wrong volume satisfies neither part cleanly. A fabricated case satisfies neither at all.
Neither part is a question of legal judgment. Whether a case is the strongest authority for a proposition is judgment. Whether the case exists in the reporter, and whether the cite resolves to it, is a question of fact that has an answer before the brief is signed. The representation in Rule 2.515 is a representation about those facts. The signer is in a position to confirm them. The rule now says the signer has represented that they were confirmed.
This is the same structure the federal sanctions orders have rested on, stated as a forward-looking rule rather than discovered after a filing failed. The duty does not run to the tool. The duty runs to the citation. Our reading of Rule 11 and the duty of inquiry walks through how that distinction has played out in the federal cases. Florida has now written the verification expectation directly into the signing rule.
What is exposed when the representation fails
The amendment authorizes a court to impose sanctions for a filing inconsistent with the representation, after the signer receives notice and an opportunity to be heard. The court identified the range. A court may issue a reprimand. A court may hold the signer in contempt. A court may strike the document. A court may dismiss the proceeding. A court may award costs and attorneys' fees. The list is not a ceiling. The court named other sanctions as available.
The exposure is broader than the sanction itself. A citation that could not be located in the reporter is a fact that appears on a public docket. It travels to the client, to the malpractice underwriter at renewal, and to opposing counsel in the next matter. The questions carriers have started asking on renewal run to exactly this point. A documented verification step is the answer the firm wants to have ready before the question is asked.
What compliance looks like operationally
The operational form of the representation is a step that happens after drafting and before filing. The step extracts every citation from the final draft. The step resolves each citation against reporter and public-record sources. The step records, for each citation, whether the case was located, whether the cited language appears in the opinion, and which source records were consulted.
The step does not write the brief. The step does not choose the authority. The step does not exercise judgment about which case best supports a proposition. The step confirms the existence and the accuracy of the citations already named in the draft. That is the narrow factual question the Rule 2.515 representation now turns on.
The signer reads the result. The result is a structured list of citations and their verification status. Citations that could not be located are surfaced. Citations whose language does not match the opinion are surfaced. The signer decides how to handle each one, and signs after reviewing the result rather than before. The representation is made on the basis of a record, not a recollection.
The certificate as the record of the representation
The representation under Rule 2.515 is owed at the moment of signing. The signature is the certification. The question a later reviewer asks is not whether the citations could have been checked. The question is whether they were, and what the check found.
A Verification Certificate is the contemporaneous record of that check. The certificate lists each citation that was checked, the verification status for each, the source records consulted, a SHA-256 hash of the certificate content, a public token URL, and the timestamp of generation. The certificate is filed in the matter file alongside the brief. The hash and the timestamp bind the record to the moment the representation was made.
The certificate does not substitute for the signer's judgment, and it does not relieve the signer of the representation. It is the artifact that the representation rested on something. When an order to show cause arrives, the signer produces the certificate. When the malpractice underwriter asks how AI-assisted citations are verified, the firm produces the certificate. The record exists outside the memory of the people who produced it.
The two weeks before June 15
The rule takes effect on June 15, 2026. Because the amendment was adopted without a prior comment period, the court has invited comments through August 11, 2026, with the rule in force in the meantime. The practical implication for a Florida practice is that the representation governs filings now, and the window to put a verification step in place before the first filing under the rule is short.
The step is the same one the federal posture has converged on, and the same one a careful Florida practice was already in a position to run. The Filing Risk Scanner extracts the citations from the draft, resolves them against reporter and public-record sources, classifies each by verification status, and produces the certificate. The signer reviews the certificate. The brief is signed. The record of the representation exists in the matter file before the filing leaves the firm.