Was Marion Parnell, Jr. v. Florida Department of Corrections sanctioned over AI-generated citations?

Marion Parnell, Jr. v. Florida Department of Corrections (CA Eleventh Circuit, July 10, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Motion to strike granted; attorney's fees for the motion granted with the amount reserved; counsel referred to the Committee on Lawyer Qualifications and Conduct. No monetary penalty in this order.

Which AI tool was involved in Marion Parnell, Jr. v. Florida Department of Corrections?

The order in Marion Parnell, Jr. v. Florida Department of Corrections does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

July 10, 2026 · AI sanctions database

Marion Parnell, Jr. v. Florida Department of Corrections

Marion Parnell, Jr. v. Florida Department of Corrections 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 Eleventh Circuit
Date: July 10, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Motion to strike granted; attorney's fees for the motion granted with the amount reserved; counsel referred to the Committee on Lawyer Qualifications and Conduct
Penalty: No monetary penalty in this order.

FineBar referralProfessional sanction

What the record shows

The Eleventh Circuit affirmed summary judgment and granted the appellee's motion to strike portions of the reply brief, which the appellee showed cited two court opinions and at least five quotations that could not be located in the court's reporters. Ordered to supply supplemental briefing, counsel stated only that he had been unable to identify a verified source and did not explain how the citations reached the brief. The court said it suspected generative artificial intelligence, granted attorney's fees for the time spent on the motion with the amount reserved for a later order, and referred the attorney to the Committee on Lawyer Qualifications and Conduct.

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 Eleventh Circuit

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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