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Florida · state appellate court · 2025

Juan Alberto Goya v. Rosa M. Hayashida

District Court of Appeal of Florida, 13 August 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Fla. Dist. Ct. App.

  1. Court. District Court of Appeal of FloridaCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 13 August 2025DATED
  4. Docket. No. 4D2023-1212DOCKET
  5. Documents. one document, 3 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, 13 August 2025 · source · PDF · 4 pages

5th DCA 2014)” for the proposition that a party claiming inherited property must provide documents of transfer or other formal proof of inheritance. These cases do not exist, and no cases stand for that proposition or various other contentions in her brief. Wife, “as a pro se litigant, was still required to adequately present [her] arguments on appeal.” Walker v.

3d DCA 1992)). “It is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases in their briefs.” Sanders v. United States, 176 Fed.

163, 169 (2025) (citing Eugene Volokh, Six Federal Cases of Self - Represented Litigants Citing Fake Cases in Briefs, Likely Because They Used AI Programs, Reason: Volokh Conspiracy (Nov. 11, 2023, 10:27 AM), 4 https://reason.com/volokh/2023/11/13/self-represented-litigants-use- ai-to-write-briefs-produce-hallucinated-citations). “An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” Park v.

What the text mentions

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Where this fits

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More from District Court of Appeal of Florida, from Florida, or from 2025. 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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