Kid International, LLC v. City National Bank of Florida

Kid International, LLC, Lichi, LLC, and Yaron Katz v. City National Bank of Florida and 2655 SW 25, LLC, No. 4D2025-2599 (Fla. 4th DCA), opinion filed October 7, 2026 (Shaw, J.; Gerber, C.J., and Lott, J., concurring). Counsel of record for appellants: Winsor Daniel Jr., of The Daniel Firm, Weston. Primary opinion: https://www.damiencharlotin.com/documents/3248/Kid_Intl_v._City_Natl_Bank_of_Fla_USA_07-10-2026.pdf ; database entry: https://www.damiencharlotin.com/hallucinations/ Timing note: decided October 7, 2026, one day before the October 8 watermark; first located through the Charlotin database update dated October 10, 2026, and missed by the October 8 sweep, so it is captured here on first reporting.

Appellants' initial brief relied heavily on a real federal case while falsely attributing admissions and fictional quotations to it, cited a hallucinated case seven times with a fictional quotation, cited another case under a wrong citation, court, and year for a proposition it does not support with a quotation it does not contain, and attributed quotations to real cases that do not contain them. After a show-cause order, counsel accepted full responsibility and explained that he had accepted his client's offer to help by supplying research materials, and that his firm had incorporated generative AI as one component of its research and drafting process; his verification process failed to catch that authorities did not exist, were inaccurately cited, or did not support the stated propositions. His attempted amended brief did not resolve all the citation issues.

The court held that submission of hallucinated and inaccurately cited case law is sanctionable, extending the reasoning of its court-initiated sanctions cases under Florida Rule of Appellate Procedure 9.410(a) to a party's motion for fees as a sanction under Rule 9.410(b). It granted the defendants' sanctions motion, disregarded the hallucinated citations and misrepresented holdings, affirmed summary judgment for the defendants, and awarded the defendants their reasonable attorney's fees incurred in litigating the appeal, with the amount to be set by the circuit court on remand. The plaintiffs and their counsel are jointly and severally liable for that award.

Client-supplied research is still the lawyer's filing: independently locate and check every authority a client hands you against an authoritative source before it goes in a brief, especially when the client's own earlier pro se complaint in the same case was already riddled with citation errors. A firm AI component needs a documented verification step that actually runs; counsel's own account was that the process failed. And when a court orders you to fix a brief, the replacement must be fully re-verified: an amended brief that leaves citation errors in place confirms the process is still broken.

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• Primary opinion: https://www.damiencharlotin.com/documents/3248/Kid_Intl_v._City_Natl_Bank_of_Fla_USA_07-10-2026.pdf
• damiencharlotin.com: https://www.damiencharlotin.com/hallucinations/