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HomeCasesFriend v. Serpa
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Corpus matter record

Friend v. Serpa

CA Florida · Dec 17, 2025

FL / stateEditorial impact: lowpro sefake citationsfamilyappellateWarning
Direct answer

What happened in this matter?

The court issued a formal warning to a pro se appellee for submitting phantom case citations. The court explicitly cautioned that litigants using artificial intelligence to assist in drafting submissions are responsible for ensuring the accuracy of their filings and may face future sanctions for non-compliance with procedural rules regarding citation integrity.

Why the court cared
Fabricated: Case Law | Appellee included multiple non-existent case citations (phantom authority); court found them fabricated and instructed they be disregarded.
Why it matters now
This record documents a Pro Se Litigant filing issue in CA Florida, with the listed outcome: Warning.

Why this matter is tracked

In Friend v. Serpa, the District Court of Appeal of Florida, Fourth District, addressed the appellee's inclusion of multiple non-existent case citations in their submissions. The court identified these as phantom authority and explicitly disregarded them. While the court affirmed the underlying merits of the case, it issued a formal admonition regarding the appellee's responsibility for the accuracy of their filings. The court specifically noted that litigants using artificial intelligence to assist in drafting submissions must ensure the accuracy of the content provided. Although the court declined to impose formal sanctions under Florida Rule of Appellate Procedure 9.410(a) in this instance, it emphasized the potential for future disciplinary action for failure to comply with procedural requirements regarding citation accuracy.

Operational lesson

This record documents a Pro Se Litigant filing issue in CA Florida, with the listed outcome: Warning.

Record details

FloridaSingle-state evidence scope
Explore FLOpen its source-linked jurisdiction page and related matters.
CourtCA Florida
Jurisdictionstate
Circuit11th Circuit
DateDec 17, 2025
AI
AI toolAI (unspecified)
Party typePro Se Litigant
OutcomeThe court affirmed the lower court's decision on the merits while issuing a formal warning regarding the appellee's use of fabricated citations.
Known amountNot recorded
Professional sanctionNone imposed; court declined to exercise its authority to sanction under Florida Rule of Appellate Procedure 9.410(a).
Attribution boundary

What the record establishes about AI use

implied

The court explicitly references those who use artificial intelligence to assist in submissions.

Procedural posture

Appellate review of a circuit court decision, resulting in an affirmance on the merits with a written opinion addressing procedural misconduct.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

1 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Appellee included multiple non-existent case citations (phantom authority); court found them fabricated and instructed they be disregarded.

Questions this record answers

What happened in Friend v. Serpa?
The court issued a formal warning to a pro se appellee for submitting phantom case citations. The court explicitly cautioned that litigants using artificial intelligence to assist in drafting submissions are responsible for ensuring the accuracy of their filings and may face future sanctions for non-compliance with procedural rules regarding citation integrity.
Why does Friend v. Serpa matter for legal AI risk?
This record documents a Pro Se Litigant filing issue in CA Florida, with the listed outcome: Warning.
What does the public record establish about Friend v. Serpa?
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Which source supports this Friend v. Serpa summary?
The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.

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