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A South Florida lawyer requests that a Miami-Dade County judge impose sanctions on the City of North Miami, the city attorney’s office, and assistant city attorney PaulMarie E. Bobb for allegedly using artificial intelligence (AI) that cited nonexistent case law in a recent court filing.
Faudlin Pierre is representing Jean Jouse Charlot in an ongoing lawsuit against the city for allegedly failing to produce public records related to Charlot’s alleged unlawful arrest by the North Miami Police Department in February 2025. According to the court documents, Pierre requested a series of records, including arrest affidavits, search warrants, body-worn camera footage, and investigative files related to the incident, from the city in August 2025.
By November, the city had not turned over all of the records, prompting Pierre to file a complaint alleging violations of Florida’s public records law, Chapter 119.
“As filing of this complaint, defendant still has not responded or produced the public records,” the November complaint reads. “This action is not bought for a frivolous purpose but a genuine need to obtain public records.”
In response to the city’s motion to dismiss, stating that it had complied with public records law and provided all records it could at the time, Pierre said the city used AI, which allegedly cited case law that does not exist.
“Administrative Order 26.04 mandates disclosure of any generative artificial intelligence used in the preparation of court filings and prohibits the submission of fictitious or unverified legal authority,” the motion for sanctions filed on February 2 reads. “The order prohibits: submission of fictitious, fabricated, or hallucinated legal authority, statutes, quotations, or facts; reliance on AI-generated citations without independent verification.”
Pierre wrote that the city cited a fake case, Kline v. Miami-Dade County, from the Florida Third District Court of Appeals.
“That case does not exist,” he said. “The only Florida appellate decision reported at 200 So. 3d 271 (2016) is Kline v. University of Miami, a First District case —not a Third District case—and it does not support the city’s asserted proposition.”
He goes on to argue that North Miami attorneys mischaracterized case law by citing cases that do not support their claims, particularly Stern v. City of Miami Beach, a case in which he served as co-counsel. He also pointed to Mazer v. Orange County and Morris v. City of Miami.
“I’m like, I was on that case. I don’t think that stands for the proposition that they’re saying,” Pierre tells New Times. “So then I started looking deeper in going into each case… and I was like, ‘Oh [they’re] using AI to kind of stop me from getting any relief under the act, meaning basically, ‘Hey, we’re going to give you the records, but you’re not entitled to any fees because we don’t believe we justifiably delayed,’ but I’m saying what you’re citing doesn’t even stand for the proprisition you’re citing it for.”
As of February 5, Pierre tells New Times he has not yet received all of the requested records, including body-worn camera footage, which he paid for.
In his motion, Pierre argued that the city’s “reliance on nonexistent and mischaracterized legal authority” constitutes sanctionable conduct.
“Florida courts have made clear that the submission of fictitious or hallucinated case, whether by counsel or a litigant, violates fundamental duties of candor and professionalism and warrants sanctions,” he added.
