ByoPlanet International, LLC v. Johansson
The case
ByoPlanet International, LLC v. Johansson et al., S.D. Fla., Nos. 0:25-cv-60630/60646/60647/60712-LEIBOWITZ, sanctions order entered July 17, 2025 (Doc. 33), against attorney James Martin Paul. Eight related cases before the court. Primary order: https://websitedc.s3.amazonaws.com/documents/Byoplanet_Order.pdf ; reported at: https://ediscoverytoday.com/2025/07/22/eight-related-cases-with-ai-hallucinations-leads-to-severe-sanctions-artificial-intelligence-trends/
What happened
Paul filed seven submissions across this and other courts containing hallucinated cases and fabricated quotations, including in a response to an order to show cause about his AI use, after the problem had already been identified.
The rule and the sanction
The court found "repeated, abusive, bad-faith conduct that cannot be recognized as legitimate legal practice and must be deterred": the four cases before the court were dismissed without prejudice and without leave to amend (with related refiled cases subject to the same treatment), Paul was ordered to pay defense counsel's attorneys' fees for all time spent responding to AI-generated filings, must attach a copy of the sanctions order to any complaint filed in the Southern District of Florida for two years, and was referred to the Florida Bar for discipline.
How it could have been avoided
Repeating the conduct after a warning, especially inside a response to a show-cause order, is treated as bad faith and can cost the client the entire case. After any AI-related judicial warning, stop filing AI-assisted work entirely until a verified workflow is in place, and disclose the issue to affected clients.