Florida Appeals Journal 44: Artificial Intelligence and the law -- Researchers beware.

FLORIDA APPEALS JOURNAL™ JOURNAL ENTRY 44.2025 Recorded on September 8, 2025

#floridaappealsjournal #appeals #floridacivilappeals #artificialintelligence #chatgpt

In this episode of Florida Appeals Journal, appellate attorney Jennifer S. Carroll explores the risks of relying on AI for legal research. With the rise of tools like ChatGPT, both lawyers and self-represented litigants are tempted by quick answers — but the courts are beginning to sanction misuse. Jennifer reviews two key cases:

• Mata v. Avianca (S.D.N.Y. 2023) — known as the first “ChatGPT case,” where an attorney submitted fictitious case citations generated by AI and faced Rule 11 sanctions.
• Garner v. Cadence (Utah Ct. App. 2025) — where fake AI-generated precedent led to violations of appellate procedure, with the court emphasizing that attorneys remain the gatekeepers for verifying the accuracy of every filing.

Jennifer stresses that while AI can be a powerful tool, attorneys (and lay researchers) must independently verify every citation to avoid professional misconduct and uphold ethical standards.

This is a must-watch for practitioners and anyone curious about how AI is reshaping legal practice.

CITATIONS
1 Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)
2 Garner v. Cadence, 571 P.3d 812 (Utah Ct. App. 2025)

For educational purposes only. Not intended to be used as legal advice.

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Music by Kevin MacLeod
Werq Kevin MacLeod (incompetech.com)
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The Law Offices of Jennifer S. Carroll, P.A. is dedicated to advocating and protecting clients’ rights in state and federal appeals, post-trial proceedings, as well as pretrial and trial proceedings that involve resolution of significant legal issues. The firm’s mandate is to provide such representation at the highest quality for all clients. By the time a case reaches our firm, it is complicated. It either started that way, or it became difficult as a result of errors which occurred in the trial court proceedings. Our goal is to simplify these difficult cases and resolve them in the best interests of all clients.

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