A U.S. federal appeals court has sharply criticized a Florida attorney after discovering that court filings he submitted contained fabricated legal citations believed to have been generated by artificial intelligence, warning that AI cannot replace a lawyer’s professional judgment or ethical obligations.
In a strongly worded order issued on Friday, the 11th U.S. Circuit Court of Appeals said attorney Anthony Sabatini filed multiple briefs in a dispute involving commercial airline employees that referenced court decisions that simply do not exist. The judges concluded the inaccurate citations resulted from an improper reliance on AI-generated legal research.
The three-judge panel stated that by depending on an AI tool to prepare legal filings without verifying its output, Sabatini failed in his duties to both his clients and the court. The judges remarked that regardless of the capabilities of artificial intelligence, it cannot serve as a substitute for genuine legal reasoning and human intelligence.
The court also announced that the chief judge of the 11th Circuit will refer Sabatini to the court’s Committee on Lawyer Qualifications and Conduct for further review of his actions.
Sabatini, who previously served in the Florida House of Representatives and currently sits on the Lake County Board of Commissioners, did not immediately respond to requests for comment.
The ruling came as the appeals court upheld a lower court’s dismissal of a lawsuit brought by current and former employees of cargo airline Atlas Air and one of its contractors. The plaintiffs had challenged workplace mask and COVID-19 vaccination policies implemented during the pandemic. Atlas Air denied any wrongdoing throughout the litigation.
The case adds to a growing list of legal proceedings highlighting the risks of using generative AI in court filings. While AI tools have become increasingly common for legal research and drafting, they are also known to produce inaccurate information, including fictional court decisions, incorrect quotations and fabricated legal authorities.
Courts across the United States have repeatedly reminded attorneys that AI-generated content must be independently verified before it is submitted as part of official legal filings. Failure to do so has resulted in sanctions and disciplinary actions against lawyers in several jurisdictions.
This was not the first time Sabatini acknowledged problems with his filings. Last year, he apologized to the appeals court after submitting documents containing what he described as “erroneous or unverifiable” case citations, attributing the mistakes to research oversights.
The appellate judges said attorneys who choose to use artificial intelligence remain fully responsible for ensuring every legal citation and argument presented to the court is accurate, emphasizing that technological convenience does not lessen a lawyer’s professional responsibilities.
