Was Russell v. Mells sanctioned over AI-generated citations?

Russell v. Mells (CA Florida, December 10, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Order to show cause issued to appellee's counsel after the court determined a cited case ('Cade v. Roberts') appeared in the brief but could not be located in any reporter and, in the court's words, 'appeared to have been hallucinated (most likely by a generative artificial intelligence program),' alongside two further citations containing misquotations.. No monetary penalty in this order.

Which AI tool was involved in Russell v. Mells?

The order in Russell v. Mells does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

December 10, 2025 · AI sanctions database

Russell v. Mells

Russell v. Mells 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
Date: December 10, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Order to show cause issued to appellee's counsel after the court determined a cited case ('Cade v. Roberts') appeared in the brief but could not be located in any reporter and, in the court's words, 'appeared to have been hallucinated (most likely by a generative artificial intelligence program),' alongside two further citations containing misquotations.
Penalty: No monetary penalty in this order.

Show causeAlleged

What the record shows

The District Court of Appeal of Florida noted that one authority cited in appellee's brief, styled 'Cade v. Roberts,' could not be located in any reporter and, per the court, 'appeared to have been hallucinated (most likely by a generative artificial intelligence program),' and that two additional citations contained misquotations. The court issued an order to show cause directing appellee's counsel to address the unverifiable and misquoted authorities.

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

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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