JMOR Properties, LLC v. Artist Alley Townhomes, LLC, Sam Kirzner, and UNB Delray Project, LLC

JMOR Properties, LLC v. Artist Alley Townhomes, LLC, Sam Kirzner, and UNB Delray Project, LLC, Fla. 4th DCA, No. 4D2026-1787, per curiam opinion on order to show cause, August 12, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-165-jmor-properties-v-artist-alley-townhomes.pdf`.

Barry M. Leff filed a certiorari petition riddled with false citations and arguments, including a nonexistent case purportedly from the Fourth District and an unsupported claim that the court had repeatedly granted certiorari review of orders vacating clerk's defaults. Leff's response acknowledged the false citations and said his normal process is to have AI software research and draft the initial document and then verify every citation, but he inadvertently filed the AI's initial draft while making final edits.

Florida Rule of General Practice and Judicial Administration 2.515(d)(2)(D) and Florida Rule of Appellate Procedure 9.410(a); the court also cited the duty of competence under Rule Regulating the Florida Bar 4-1.1. Sanction: referral of Leff to the Florida Bar for consideration of disciplinary proceedings. Flag: the opinion states it is not final until disposition of a timely-filed motion for rehearing.

Keep AI drafts and verified drafts in separate, clearly labeled files, and confirm the filed version is the verified one before submission. "Wrong draft" does not excuse filing unverified authority, and the revised draft still omitted clearly established contrary law.

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