In re Thomas Grant Neusom

Why this matter warrants attention

Outcome: Suspension from practice before the Middle District of Florida for one year; immediate prohibition on accepting new federal matters; conditional reinstatement. (Grievance Committee Report available here.)AI UseNeusom told the grievance committee that he “may have used artificial intelligence” in preparing filings, and that any hallucinated cases were not deliberately fabricated but may have come from AI tools. The filings in question included a notice of removal and a motion for summary judgment. The judge later noted a pattern of citations inconsistent with established case law and unsupported by known databases.Hallucination DetailsCitations included cases that either did not exist or were grossly mischaracterized. Notably:Southern Specialties, Inc. v. Pulido Produce, Inc. – no such case found in Westlaw, Lexis, or PACERTrilogy Communications v. Times Fiber – cited in support of breach of contract when it was a patent matter involving no such principlesNeusom failed to produce the full texts of the cited cases when requested and instead filed a 721-page exhibit in violation of court orders.Ruling/SanctionThe court adopted the grievance committee’s recommendation and imposed a one-year suspension. Neusom is prohibited from accepting new federal cases in the Middle District of Florida during the suspension and must:Notify existing clients and the court of his suspensionFile a compliance affidavit within 30 daysComplete appropriate CLE and counseling programsRemain in good standing with the Florida BarApply for reinstatement only after certifying complianceKey Judicial ReasoningThe court found that Neusom violated Rules 4-1.3, 4-3.3(a)(3), 4-3.4(c), and 4-8.4(c) of the Florida Rules of Professional Conduct. His failure to verify AI-generated content, compounded by noncompliance with orders and false statements to opposing counsel, demonstrated a pattern of recklessness and dishonesty. The court emphasized that federal proceedings require a high standard of diligence and that invoking AI cannot excuse failure to meet professional obligations.