Case D-29 · AI Sanctions Case Tracker

In re Thomas Grant Neusom

U.S. District Court for the Middle District of Florida, Opinion and Order entered March 8, 2024

The case

In re Thomas Grant Neusom, M.D. Fla., No. 2:24-mc-2-JES, Opinion and Order entered March 8, 2024 (Doc. 6): one-year suspension from the Middle District of Florida bar. Primary order: https://cases.justia.com/federal/district-courts/florida/flmdce/2:2024mc00002/423605/6/0.pdf?ts=1710086217 ; reported January 2025 by the Maryland State Bar Association: https://www.msba.org/site/site/content/News-and-Publications/News/General-News/Faux-AI-Cases-Lead-to-Suspension.aspx

What happened

Per the Maryland State Bar Association's reporting on the matter, Neusom filed materials with inaccurate (AI-generated) authorities without verifying citations, repeatedly ignored local rules and court directions, and behaved unprofessionally toward opposing counsel (yelling, hanging up, baseless accusations causing delay and harm).

The rule and the sanction

The court found violations of Florida Bar Rule 4-1.3 (diligence), Rules 4-3.3(a)(3) and 4-8.4 (candor and misconduct, covering citing inaccurate authority and fabricating authorities), and Rule 4-3.4(c) (disobeying court rules and orders). Sanction: Neusom was suspended from the Bar of the Middle District of Florida for one year and prohibited from taking new cases in the district until reinstated under specified conditions.

How it could have been avoided

AI misuse combined with incivility and disregard of court orders compounds exponentially: each category of misconduct supports the others at sentencing. Verify authorities, follow local rules and court orders to the letter, and maintain professional communication even under stress.

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