Straub v. Henderson Trust - Appeal Disposition
Summary
The Florida District Court of Appeal affirmed a lower court's decision in Straub v. Henderson Trust. The opinion references the growing concern over AI-generated content and fake case citations in legal filings, citing previous cases that addressed similar issues.
What changed
The Florida District Court of Appeal, Second District, affirmed the lower court's decision in the case of Straub v. Henderson, Margaret McShane Revocable Trust. The disposition of 'Affirmed' indicates the appellate court upheld the trial court's ruling. The opinion specifically cites previous Florida appellate decisions that have addressed the dangers of relying on generative artificial intelligence and the proliferation of fake or hallucinated case citations in court filings.
This ruling serves as a reminder to legal professionals regarding the importance of verifying case citations and the potential consequences of submitting filings with fictitious or nonexistent case law. While this specific case was affirmed, the included citations highlight judicial concern over the integrity of legal research and filings, particularly in light of emerging AI technologies. Legal professionals should ensure their filings are accurate and adhere to established citation standards to avoid potential sanctions or procedural issues.
What to do next
- Review internal policies on legal research and citation verification.
- Ensure all court filings are meticulously checked for accuracy of case citations and legal propositions.
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Feb. 25, 2026 Get Citation Alerts Download PDF Add Note
Straub v. Henderson, Margaret McShane Revocable Trust
District Court of Appeal of Florida
- Citations: None known
- Docket Number: 2D2025-1787
Disposition: Affirmed
Disposition
Affirmed
Combined Opinion
DISTRICT COURT OF APPEAL OF FLORIDA
SECOND DISTRICT
CHRISTOPHER STRAUB,
Appellant,
v.
MELISSA HENDERSON, as Successor Trustee of the
Margaret McShane Revocable Trust Dated March 24, 2016,
Appellee.
No. 2D2025-1787
February 25, 2026
Appeal from the Circuit Court for Hillsborough County; Emily A.
Peacock, Judge.
Christopher Straub, pro se.
Marc C. Mann of Berlin Patten Ebling PLLC, Tampa, for Appellee.
PER CURIAM.
Affirmed. See Clerk of Ct. & Comptroller for 13th Jud. Cir.,
Hillsborough Cnty. v. Rangel, No. 2D2024-1772, 2025 WL 2486314, at *2
(Fla. 2d DCA Aug. 29, 2025) ("[T]he dangers of relying on generative
artificial intelligence have been discussed in the media, in legal
publications, and in court opinions."); Takefman v. Pickleball Club, LLC,
418 So. 3d 826, 827 (Fla. 3d DCA 2025) ("We write, however, to address
an issue of growing concern—the proliferation of fake or hallucinated
case citations in court filings. . . . Opposing counsel, and the court,
should not have to parse case citations and parentheticals to discern
whether cases exist, and if so, if they stand for the propositions
asserted."), reh'g denied (Sept. 11, 2025); Goya v. Hayashida, 418 So. 3d
652, 655 (Fla. 4th DCA 2025) ("An attempt to persuade a court or oppose
an adversary by relying on fake opinions is an abuse of the adversary
system." (quoting Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024))); see
also Gutierrez v. Gutierrez, 399 So. 3d 1185, 1187-88 (Fla. 3d DCA 2024)
(dismissing pro se appellant's appeal and imposing sanctions for filing
briefs that contained "fictitious and nonexistent case law").
LUCAS, C.J., and NORTHCUTT and ATKINSON, JJ., Concur.
Opinion subject to revision prior to official publication.
2
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