Parnell v. Florida Department of Corrections
The case
Parnell v. Fla. Dep't of Corr., 181 F.4th 1209 (11th Cir. July 10, 2026) (per curiam, No. 25-11166). Primary opinion: https://www.damiencharlotin.com/documents/2594/Parnell_v._Florida_Dep_Cor._USA_10_July_2026.pdf
What happened
Counsel Dufirstson J. Neree filed a reply brief citing two nonexistent opinions and at least five nonexistent quotations. The court suspected AI hallucinations, and counsel could not explain the source of the authorities when questioned.
The rule and the sanction
The court granted the motion to strike the offending brief and granted the motion for attorney's fees and sanctions (fee amount reserved; the Department of Corrections to file an affidavit). Neree was referred to the Eleventh Circuit's Committee on Lawyer Qualifications and Conduct under Addendum Eight, Rule 2. Notably, the opinion cites both Charlotin's AI-hallucination tracker and Florida Rule 2.515(d)(2), a federal appellate court invoking the state's AI filing rule.
How it could have been avoided
When a court asks "where did this authority come from," "I don't know" is the worst possible answer, be able to trace every citation to an actual database pull. Reply briefs need the same verification as opening briefs; shorter filings are not lower-stakes. Note the institutional development: the Eleventh Circuit now routes AI-misconduct through a formal qualifications-and-conduct committee, so a single bad brief can follow a lawyer beyond the case.