Capital Standard, LLC et al. v. U.S. Bank National Association

Capital Standard, LLC et al. v. U.S. Bank National Association, Fla. 2d DCA, No. 2D2024-1392, opinion filed August 21, 2026 (Judge Rothstein-Youakim). Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-166-capital-standard-v-us-bank.pdf`.

Kenneth Keefe used a generative AI tool as his primary or only research tool from the beginning of the appeal. His amended initial brief contained at least 31 AI hallucinations (nonexistent quotations with fake pin cites, real cases cited for propositions they do not contain) and his reply brief added 15 more, including the fake case Board of Regents v. Wilson. After a detailed January 8, 2026 show-cause order documented all 46 hallucinations, Keefe ignored it for more than a month and responded only after the court struck the briefs and ordered him to notify his clients.

Florida Rules of Appellate Procedure 9.410(a) and 9.210(b)(5), and Florida Rule of General Practice and Judicial Administration 2.515(d). Sanctions: a $1,500 fine payable to the clerk ($1,000 for the AI misuse, $500 for the belated response to the show-cause order); Keefe personally ordered to pay U.S. Bank's attorney fees incurred in researching and answering the amended initial brief, the amount to be determined on remand to the trial court, with Keefe barred from charging his clients; referral to the Florida Bar; the offending briefs struck.

Verify every AI-generated citation against the actual opinion before filing, and never ignore a show-cause order. The $500 add-on fine and the client-notification order flowed from the month of silence, not from the original hallucinations.

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