Hodges v. Meridian Waste Acquisitions, LLC

Hodges v. Meridian Waste Acquisitions, LLC, Case Nos. 3:25-cv-62 and 5:25-cv-45 (M.D. Fla.), sanctions order following a January 13, 2026 hearing. Primary order: https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00062-53-3-cv

Plaintiff's counsel admittedly filed briefs in two cases containing AI-generated fake citations.

The court reiterated that "lawyers are ethically bound in all court filings to provide true and accurate record and case citations" and that AI as a research tool "does not alter this basic requirement of candor to the tribunal." Upon discovery, counsel took corrective steps: efforts to withdraw the filings, paying defendants $7,000 in fees (3:25-cv-62), reducing his own fees (5:25-cv-45), completing multiple ethics CLEs, arranging CLE for his law firm, alerting the clients involved, and apologizing to the court and defense counsel. As a further sanction, the court required counsel to complete ten speaking engagements to bar associations or law students by January 29, 2027, with a compliance certification (ORDER, pp. 3–4). The court expressly declined to refer counsel to the Middle District Grievance Committee or the Florida Bar (ORDER, p. 3).

Verify before filing; but if prevention fails, this case models the mitigation playbook courts reward: prompt withdrawal, voluntary fee payments, and relevant CLE: the opposite of the denial-and-delay pattern that draws harsher sanctions elsewhere.

• Primary order: https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00062-53-3-cv