Mikka Glenn v. Absolute Resolutions Investments, LLC

Mikka Glenn v. Absolute Resolutions Investments, LLC, et al., No. 3:25-cv-198-TJC-LLL (M.D. Fla., Jacksonville Division), order filed October 9, 2026. Plaintiff's counsel is not named in the order. Primary order: https://www.damiencharlotin.com/documents/3288/Mikka_Glenn_v._Absolute_Resolutions_Investments_United_States_09-10-2026.pdf ; database entry: https://www.damiencharlotin.com/hallucinations/ Timing note: the order is dated October 9, 2026, but it first surfaced in the Charlotin database update of October 16, 2026, after the October 15 sweep (which recorded no decisions dated after October 8), so it is captured here on first reporting.

Plaintiff's counsel filed a memorandum of law containing at least two fake citations: one case was nonexistent, and another did not contain the quotation attributed to it. Counsel then filed two notices of errata to correct errors in the memorandum, which is how the court discovered the fake citations. The underlying case settled, but the court still scheduled a hearing (held October 1, 2026) to investigate. At the hearing, counsel explained that, in his haste to meet a filing deadline, he had failed to properly review a document that included materials generated by research conducted using AI. The court recorded that he was candid about his carelessness and embarrassed to be before the court.

No court-imposed sanction, NO FURTHER ACTION ORDERED. The court restated the duty of candor to the tribunal, quoting its January 16, 2026 order in Hodges v. Meridian Waste Acquisitions, LLC (D-27): lawyers "are ethically bound in all court filings to provide true and accurate record and case citations," AI "does not alter this basic requirement of candor to the tribunal," and taking "the shortcut of relying on AI or the assistance of others without verification" is "not acceptable conduct; it will not be tolerated." The court nonetheless held that the remediation counsel had already completed before the hearing was "a suitable remedy": he had told and apologized to his client; told and apologized to opposing counsel (who advised they had not been prejudiced); gave the entirety of his fee in the case, an amount approximating $10,000, to Jacksonville Area Legal Aid; attended 7.5 hours of CLE courses on AI ethics; described a number of changes to his office procedures designed to prevent a recurrence; and apologized to the court at the hearing. The court was "satisfied that counsel understands the gravity of his actions and will not repeat them," determined that "no further action will be necessary," and left the file closed. Flag: the $10,000 was a voluntary pre-hearing remediation step credited by the court, not a fine imposed by the court, do not present it as a court-ordered penalty.

R1, Owned It Early (correction began with counsel's own errata; full remediation completed before the hearing; court held the remediation "a suitable remedy" and ordered no further action).

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The filing failure is the familiar one: a deadline is not a verification process, review every authority in AI-assisted research before filing, because two fake citations in a single memorandum (one invented case, one invented quotation) are enough to trigger a court investigation even after the case settles. The outcome, though, is the mitigation lesson: remediation completed before the sanctions hearing, not promised after it, is what persuaded the court to close the file with no further action. Counsel who discovers an AI error should notify the client and opposing counsel, apologize in person, complete relevant AI-ethics CLE, document changed office procedures, and be candid and embarrassed rather than defensive at the hearing. Settlement does not moot the court's interest in a filing's accuracy.

• Primary order: https://www.damiencharlotin.com/documents/3288/Mikka_Glenn_v._Absolute_Resolutions_Investments_United_States_09-10-2026.pdf
• damiencharlotin.com: https://www.damiencharlotin.com/hallucinations/