The Florida Bar v. Thomas Grant Neusom
The case
The Florida Bar v. Thomas Grant Neusom, No. SC2024-0611 (Fla. Jan. 16, 2025), 2025 WL 211543; Lower Tribunal Nos. 2019-50,315(17H) and 2024-50,631(17H). A reciprocal-discipline proceeding: the Florida case rests on the Middle District of Florida suspension (D-29, Count I) and a 2018 Southern District of Florida Bankruptcy Court sanction (Count II). The matter first entered this library unidentified, via Florida Bar President-elect Rosalyn Sia Baker-Barnes's December 2025 testimony to a Florida House panel; the identification was established in the full pass from the Florida Bar's own discipline documents, the Formal Complaint for Reciprocal Discipline (Apr. 25, 2024), the Report of Referee (Oct. 24, 2024), and the Supreme Court order (Jan. 16, 2025).
What happened
The AI-citation conduct sits in the federal predicates, in the Middle District matter (D-29), Neusom filed materials with fabricated AI-generated authorities. In the Florida proceeding, the referee recorded a "refusal to acknowledge the wrongful nature of the conduct"; Neusom had also filed an Amended Complaint with racketeering allegations against opposing counsel after a remand order, filed a written response that did not address the fabricated citations, and failed to appear at the final disciplinary hearing.
The rule and the sanction
The Supreme Court of Florida approved the referee's report and suspended Neusom for two years, effective 30 days from the order, barred him from new business until reinstatement, and entered a costs judgment of $2,710.50 (ORDER, p. 1). The suspension is reciprocal discipline resting on the federal predicates (D-29 and the 2018 bankruptcy sanction), not a direct prosecution for the AI pleading itself. Source: https://www.floridabar.org/the-florida-bar-news/baker-barnes-briefs-house-panel-on-ai-ethics-discipline-and-emerging-safeguards/
How it could have been avoided
Reciprocal discipline means one AI-citation episode follows a lawyer across courts: the Middle District suspension and an earlier bankruptcy sanction were consolidated into a two-year Florida suspension. The response failures compounded it, a written response that never addressed the fabricated citations, and a failure to appear at the final hearing, left the referee recording a refusal to acknowledge the conduct.