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Federal · federal court of appeals · 2026

Estate of Lane Caviness v. Atlas Air, Inc.

Court of Appeals for the Eleventh Circuit, 10 July 2026. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · 11th Cir.

  1. Court. Court of Appeals for the Eleventh CircuitCOURT
  2. Level. federal court of appealsLEVEL
  3. Date. 10 July 2026DATED
  4. Docket. No. 24-11033DOCKET
  5. Documents. one document, 5 passages quoted belowON FILE
  6. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Published opinion, 10 July 2026 · source · PDF · 14 pages

Sabatini has not been candid with us. Sabatini filed multiple briefs replete with fake and hallucinated citations. Even after being warned.

The plaintiffs’ counsel Anthony F. Sabatini’s filings are riddled with citations to nonexistent, “hallucinated” cases. His opening brief relies on at least eight such cases, including one purportedly decided by this Court.

2d 703 (Fla. 3d DCA 2008); Draper USCA11 Case: 24-11033 Document: 72-1 Date Filed: 07/10/2026 Page: 11 of 14 12 Opinion of the Court 24-11033 acknowledged in his (untimely) proposed reply brief that those citations were “erroneous or unverifiable,” and sought to withdraw his reliance on eight listed cases.6 At this point, things go from bad to worse: the eight cases Sabatini “withdrew” did not match a single one of the eight hallucinated cases in his opening brief. And not only were they not the right cases — all eight were also hallucinated.

And not only were they not the right cases — all eight were also hallucinated. We are far from the first court to see lawyers uncritically rely on artificial intelligence software and submit briefs citing nonexistent cases. See Chief Justice John G.

This tendency presents a particular USCA11 Case: 24-11033 Document: 72-1 Date Filed: 07/10/2026 Page: 13 of 14 14 Opinion of the Court 24-11033 on briefs filled with hallucinated citations — not once but twice — Sabatini violated his professional obligations, both to his clients and to this Court.

What the text mentions

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Where this fits

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More from Court of Appeals for the Eleventh Circuit, from Federal, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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