Richard Paul Smith v. Verra Mobility Corporation et al.
The case
Richard Paul Smith v. Verra Mobility Corporation et al., M.D. Fla., No. 8:25-cv-2300-KKM-NHA, 2026 WL 1197241, order filed May 1, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-144-smith-v-verra-mobility.pdf`.
What happened
Jeffrey Sullivan acknowledged using ChatGPT and other AI tools to prepare a filing without independently checking the authorities the tools produced.
The rule and the sanction
The court grounded the violation in Rule 11(b)(2), enforced through Rule 11(c)(1) and (3), and found the failure to verify negligent. The court ordered Sullivan to provide the show-cause order, his response, and the sanction order to his client, the School Board of Polk County (Tier 2 client-notice sanction).
How it could have been avoided
Independently verify every AI-generated citation against the actual opinions before filing. Disclose and check AI-assisted research rather than treating the output as finished work product.
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