Russell v. Mells
CA Florida · Dec 10, 2025
- Jurisdiction
- state
- Court
- CA Florida
- Record ID
- russell-v-mells-2025-12-10-2
- Observed outcome
- Bar Referral
- Known monetary consequence
- Not recorded
Why this matter warrants attention
Fabricated: Case Law | Appellee's brief cited a nonexistent case, 'Cade v. Roberts, 403 So. 2d 516 (Fla. 5th DCA 1981)'; court found no reported case by that name and that the cited reporter page pertained to an unrelated opinion (Girardeau v. State). Outcome: Bar Referral. "Unfortunately, we're finding this problem arising more and more frequently […] When a lawyer cites imaginary legal authorities to our court as if they were law, we are compelled to refer that lawyer to the Bar because of the professional rules of conduct. It doesn't take much moral imagination to understand why. As judges, we rely on attorneys to ethically represent their clients.…
Fabricated: Case Law | Appellee's brief cited a nonexistent case, 'Cade v. Roberts, 403 So. 2d 516 (Fla. 5th DCA 1981)'; court found no reported case by that name and that the cited reporter page pertained to an unrelated opinion (Girardeau v. State). || Misrepresented: Case Law | Two other Southern Reporter cases cited in the answer brief were misquoted—the brief attributed quoted text to the wrong cases (quotations found in different opinions than those cited).
Florida appellate panel published a naming-and-shaming opinion — assume every fabricated cite becomes a bar referral of public record.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Bar Referral
- Tort
- Appellate
- AI attribution
- Not Established
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Bar Referral
reason.com
Secondary or other linked source. The recorded link is not classified as an official court source or docket mirror.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The current record does not establish a specific AI tool. Do not infer AI use beyond the source.
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.
Latest evidence review: Secondary Source Only (medium confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Retain a matter-level record of source checks and corrections.