Was Kid International, LLC v. City National Bank of Florida and 2655 SW 25, LLC sanctioned over AI-generated citations?

Kid International, LLC v. City National Bank of Florida and 2655 SW 25, LLC (CA Florida (4th), October 7, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Summary judgment affirmed; defendants' motion for sanctions granted; plaintiffs and counsel jointly and severally liable for reasonable appellate attorney's fees, amount to be set by the circuit court on remand. No monetary penalty in this order.

Which AI tool was involved in Kid International, LLC v. City National Bank of Florida and 2655 SW 25, LLC?

The order in Kid International, LLC v. City National Bank of Florida and 2655 SW 25, LLC does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

October 7, 2026 · AI sanctions database

Kid International, LLC v. City National Bank of Florida and 2655 SW 25, LLC

Kid International, LLC v. City National Bank of Florida and 2655 SW 25, LLC is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: CA Florida (4th)
Date: October 7, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Summary judgment affirmed; defendants' motion for sanctions granted; plaintiffs and counsel jointly and severally liable for reasonable appellate attorney's fees, amount to be set by the circuit court on remand
Penalty: No monetary penalty in this order.

FineShow cause

What the record shows

The Fourth District Court of Appeal of Florida affirmed summary judgment on limitations grounds, then granted the defendants' sanctions motion. Its independent review found the initial brief cited Ogilvie v. Sebring Airport Authority seven times, a case the court called hallucinated and non-existent, attributed quotations to real opinions that do not contain them, and misstated holdings. Responding to an order to show cause, counsel admitted certain authorities did not exist as cited and said the firm used generative AI as one component of research and drafting, alongside materials supplied by the client; no specific tool was named. The court noted that the plaintiffs' earlier pro se complaint cited fifteen non-existent cases among thirty-two. It disregarded the affected citations, extended its sanction precedents to a party's motion under Rule 9.410(b), and awarded appellate attorney's fees in an amount not yet set.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · CA Florida (4th)

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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