A Florida Lawyer is facing sharp criticism after an appellate court rejected her brief for using inaccurate, AI-generated citations and for letting another attorney sign her apology. The court has now referred the issue to The Florida Bar, signaling growing pressure on lawyers to supervise artificial intelligence carefully and take full responsibility for their filings.
Citations From AI Trigger Major Concerns
The case involves attorney Sara Evelyn McLane, who represented a personal representative in an appeal before Florida’s Second District Court of Appeal. McLane cited only three cases to support her argument. Each one had a serious flaw. Two quotes were wrong, and the third case did not exist at all.
The court reviewed the citations and found reporter numbers linked to an unrelated criminal contempt case involving a state lawmaker. The mistakes showed that the brief lacked proper verification. The Florida Lawyer later admitted the citations came from “computer-based searches,” which the court understood as a reference to generative AI.
McLane also admitted she did not check the citations before filing the brief. The court said this lapse created a risk because judges might rely on fake or distorted legal principles when reviewing an appeal.
Unsigned Apology Adds to Court’s Frustration
The situation worsened when the apology letter submitted in response to the court’s order did not contain McLane’s signature. Instead, another attorney signed the filing.
The court said a Florida Lawyer must sign her own response when she is asked to explain errors. Delegating that role made a “poor impression,” and the court stressed that personal accountability is essential. The judges announced that all future responses to show-cause orders must be signed directly by the attorney involved.
Chief Judge Matthew C. Lucas said the mistake was avoidable and showed a lack of professional responsibility.
Court Labels the Filing “Deeply Troubling”
The ruling, issued in Russell v. Mells (No. 2D2024-1560) on December 10, 2025, focused on the broader dangers of AI misuse. The judges described the brief as “deeply troubling.” They emphasized that fake citations are not clerical errors. They can mislead courts and harm the justice process.
The court also rejected McLane’s argument that her legal analysis was still correct despite the flawed citations. Judges explained that legal reasoning must rest on real and verifiable authority. Without that foundation, the analysis loses credibility.
A Warning for Every Florida Lawyer Using AI
This case is not the first AI-related issue seen by Florida appellate courts. Earlier in 2025, the same court referred another lawyer to The Florida Bar for relying on unverified AI-generated case law. In that order, the court said that even when technology assists in research, a lawyer must apply “human oversight.”
The latest ruling shows that warnings have not been enough. The court said AI citation errors continue to appear in briefs, wasting judicial time and weakening trust in legal filings. The panel reminded lawyers that they must check every authority they submit, whether obtained from a database or a generative AI tool.
Potential Discipline Ahead for the Florida Lawyer
By referring McLane to The Florida Bar, the court has opened the door to possible discipline. Regulators may review whether the Florida Lawyer failed in her duties of competence, diligence, and candor. Across the country, bar authorities have treated AI-related filing errors as ethical concerns, especially when attorneys do not supervise the technology properly.
The referral signals that Florida courts expect lawyers to adapt to AI responsibly. AI can summarize cases and draft documents quickly, but it can also create fake citations and misquote real opinions. Lawyers must understand those risks and verify every claim before filing.
A Warning for Every Florida Lawyer Using AI
This situation is a clear message to every Florida Lawyer and to attorneys nationwide: AI may support the work, but it cannot replace professional judgment. Courts want accuracy, transparency, and personal accountability. When a lawyer signs a brief, the court expects that lawyer to have checked every line.
As legal technology continues to grow, attorneys must raise their standards rather than lower them. The McLane case marks an important point in that transition. It shows how errors from AI and a failure to take ownership of them can lead to disciplinary action.
The matter will now proceed to The Florida Bar, where regulators will decide the next steps. For the legal profession, however, the lesson is already clear: lawyers must supervise AI, verify all citations, and personally stand behind every filing they submit.
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