Federal · federal court of appeals · 2026

Marion Parnell, Jr. v. Florida Department of Corrections

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. 25-11166DOCKET
  5. Documents. one document, 4 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 · 6 pages

The FDOC has moved for sanctions under Federal Rule of Appellate Procedure 27 and our inherent authority, seeking attor- ney’s fees and to strike portions of Parnell’s reply brief. The FDOC argues that Parnell’s reply brief cites two non-existent court opin- ions and at least five non- existent quotations from our opinions. Parnell responds that he withdraws any erroneous statement s in his reply brief, which renders the FDOC’s motion “moot.” He ar- gues that the errors were not made in bad faith and his reply brief’s arguments are still legally correct.

We ordered supplemental briefing to provide Parnell’s counsel the opportunity to explain where the defective cases and USCA11 Case: 25-11166 Document: 41-1 Date Filed: 07/10/2026 Page: 4 of 6 25-11166 Opinion of the Court 5 quotes came from, but counsel merely repeats that he has been un- able to identify a verified source with the non-existent opinions and that “the challenged material did not come from a verified review of the cited opinions.” Counsel does not provide an exp lanation for how the opinions appeared in the reply brief.1 We are disappointed with counsel’s lack of forthcoming can- dor.

Courts around the world currently face a well-publicized problem of attorneys citing hallucinated authorities. See Damien Charlotin, AI Hallucination Cases , https://perma.cc/U84C-WGA7 (last visited May, 22, 2026) (listing over 1000 judicial decisions deal- ing with AI hallucinations). Presumably, counsel wrote the reply brief,2 and should thus be familiar with how he came to rely on the nonexistent authorities.

Presumably, counsel wrote the reply brief,2 and should thus be familiar with how he came to rely on the nonexistent authorities. Whether the appellant’s citations were generated by AI, as we suspect, or simply made up by counsel, we 1 It seems as though counsel has relied on generative artificial intelligence (AI) in writing his reply brief, as seen through the “hallucinated” cases. See Thomas J Donlon, AI Hallucinations Are Real — and How to Avoid Them , Am.

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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