Artificial intelligence is rapidly transforming the legal profession. Attorneys are increasingly using generative AI tools to assist with legal research, drafting, and document review. While these technologies can improve efficiency, they also create significant risks—particularly when AI generates inaccurate or entirely fabricated legal citations.
Recognizing these concerns, the Florida Supreme Court recently amended Florida Rule of General Practice and Judicial Administration 2.515(d)(2). Effective June 15, 2026, every attorney or self-represented litigant who signs and files a document in a Florida court now certifies that the legal authorities cited in the filing exist and are accurately cited.
What Changed?
The amendment makes citation accuracy an express certification accompanying every court filing. By signing a pleading, motion, or other filing, the signer represents that the legal authorities referenced are genuine and accurately cited.
Courts also now have express authority to impose sanctions for violations of the rule, including striking filings, awarding attorneys’ fees and costs, dismissing proceedings, holding parties in contempt, or imposing other appropriate sanctions.
Why This Matters
The rule reflects a growing reality of modern litigation: generative AI can produce legal authorities that appear convincing but simply do not exist. These ‘AI hallucinations’ have already resulted in sanctions against attorneys across the country and have raised concerns about preserving the integrity of judicial proceedings.
Rather than requiring attorneys to disclose whether AI was used, the Florida Supreme Court chose a practical approach—placing responsibility where it belongs: on the accuracy of the legal authorities presented to the court.
The amendment also replaces the varying AI-related administrative orders previously adopted by individual judicial circuits with a single statewide standard.
Practical Takeaways
AI can be an effective tool, but it is not a substitute for professional judgment. Attorneys should continue to independently verify every authority before filing any document with the court.
- Confirm that every cited case, statute, rule, and secondary source actually exists.
- Verify that each citation is accurate and complete.
- Check that authorities remain good law and have not been overruled or otherwise negatively treated.
- Ensure each citation supports the legal proposition for which it is offered.
- Maintain a reliable citation review process whenever AI-assisted research or drafting is used.
Final Thoughts
The Florida Supreme Court’s amendment reinforces a longstanding principle of legal practice: attorneys remain responsible for the accuracy of every filing submitted to the court, regardless of the technology used to prepare it.
As AI becomes more integrated into litigation, practitioners who embrace these tools while maintaining rigorous quality-control procedures will be best positioned to serve their clients effectively and avoid unnecessary risk.
If your business is involved in a commercial dispute or you have questions about how evolving legal developments may affect your litigation strategy, the litigation attorneys at Greenspoon Marder LLP are available to assist.
Meagan Nicholson is an associate in Greenspoon Marder’s Commercial Litigation practice. She represents businesses and individuals in complex commercial disputes in state and federal courts throughout Florida and the country. Her practice includes business, real estate, intellectual property, and other complex commercial litigation matters.
