Was Washington, Washington v. Justice, Crist sanctioned over AI-generated citations?

Washington, Washington v. Justice, Crist (CA Florida (2d), October 7, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Appeal dismissed under Rule 9.410(a); clerk directed to place in an inactive file further pro se filings related to the lower tribunal case; no monetary sanction. No monetary penalty in this order.

Which AI tool was involved in Washington, Washington v. Justice, Crist?

The order in Washington, Washington v. Justice, Crist 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

Washington, Washington v. Justice, Crist

Washington, Washington v. Justice, Crist 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 (2d)
Date: October 7, 2026
Party: Pro Se Litigant
AI tool: Not identified in the order
Outcome: Appeal dismissed under Rule 9.410(a); clerk directed to place in an inactive file further pro se filings related to the lower tribunal case; no monetary sanction
Penalty: No monetary penalty in this order.

Dismissal

What the record shows

The Second District Court of Appeal of Florida could not locate eleven cases cited in the initial brief of two self-represented appellants and ordered them to supply copies or show cause. They supplied no copies and described the citations as scrivener's errors. Their response neither admitted nor denied using generative AI; the court said AI was the likely source but that its concern was the reliance on what it called fictitious cases, whatever the source. No specific tool was named. The court held it could sanction without applying amended Rule 2.515(d)(2)(D) retroactively. Citing the citations, the response, and a pattern of frivolous filings across three proceedings, it stated that it dismissed the appeal and limited related future pro se filings to those signed by a Florida Bar member, apart from proceedings already pending. The opinion's closing line reads "Affirmed."

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 (2d)

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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