Was Rose Lannquist Gouldy v. Timothy Michael Chiasson sanctioned over AI-generated citations?

Rose Lannquist Gouldy v. Timothy Michael Chiasson (CA Florida (4th), July 22, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Affirmed in all respects; separate order to show cause why appellant should not be barred from further pro se filings. No monetary penalty in this order.

Which AI tool was involved in Rose Lannquist Gouldy v. Timothy Michael Chiasson?

The order in Rose Lannquist Gouldy v. Timothy Michael Chiasson 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 22, 2026 · AI sanctions database

Rose Lannquist Gouldy v. Timothy Michael Chiasson

Rose Lannquist Gouldy v. Timothy Michael Chiasson 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: July 22, 2026
Party: Pro Se Litigant
AI tool: Not identified in the order
Outcome: Affirmed in all respects; separate order to show cause why appellant should not be barred from further pro se filings
Penalty: No monetary penalty in this order.

Show causeAlleged

What the record shows

Florida's Fourth District Court of Appeal affirmed an appellate fee award and issued a separate order to show cause why the self-represented appellant should not be barred from further pro se filings. The court stated her initial brief cited a case that does not exist, attributed quotations to real Florida decisions that do not contain them, and relied on cases that do not support the propositions cited. In its conclusion the court described a growing pattern of self-represented filings that appear to be generated by artificial intelligence platforms and contain phantom authority, but it made no finding that this appellant used such a tool. She had been warned twice before against frivolous filings.

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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