FLORIDA’S SIXTH DISTRICT STANDS FIRM AGAINST IRRESPONSIBLE RELIANCE ON ARTIFICIAL INTELLIGENCE

Roy Diaz
4 hours ago
3 min read

On June 26, 2026, the Sixth District issued a written opinion requiring “pro se filer” Jaime Davidson (“Davidson”) to show cause why sanctions should not be imposed based on Davidson’s failure to comply with newly amended i Florida Rule of General Practice and Judicial Procedure 2.515. Specifically, Davidson’s initial brief inaccurately cited legal authorities or cited “non-existent legal authorities” in violation of rule 2.515(d)(2). Davidson v. Chang-Warner, 2026 Fla. App. LEXIS 4936 (Fla. 6fh DCA June 26, 2026).

The Sixth District is one of the first appellate districts to enforce rule 2.515(d)(2) as amended and issued the show cause order in response to a pro se brief which, surprisingly, was filed nearly nine months before the amendment took effect ii. The Court provided multiple reasons why reliance on the amended version of the rule was appropriate and used the majority of its opinion to explain why application of the amended version of rule 2.515 did not constitute improper retrospective iii application. iv

Firstly, the Court explained that pre-amendment rule 2.515(d) and cases applying that rule required both attorneys and pro se filers to ensure the accuracy of their filings and allowed for the imposition of sanctions against non-complying parties.v As the Court explained, rule 2.515(d)(2) “now explicitly states” what the prior version “already required.”

Secondly, citing to a 1960 Florida Bar case, the Court explained that “the primary function of trial court proceedings is to find the truth” so, independent of any procedural rules, documents filed in Florida courts could never “cite non-existent legal authorities or cite legal authorities inaccurately.”vi The Court elaborated that a “system that depends on an adversary’s ability to uncover falsehoods is doomed to failure…” so documents filed with the court must be truthful.vii

Thirdly, the Court explained that it has “always had the inherent authority to maintain the integrity of the proceedings before [the court]” and clarified that this authority included imposition of sanctions on those who abuse the legal system through irresponsible reliance on AI.viii Lastly, the court summarized that since “no new legal consequences” will result from application of amended rule 2.515(d)(2) the Court’s application of that rule was not retrospective and could be relied upon to preserve the integrity of Florida’s court system.

Notably, the Court provided Davidson until July 6, 2026, to respond to its show cause order.ix Davidson responded on the deadline by moving to withdraw the non-compliant brief and by seeking leave to file a “corrected”brief. To date, the show cause order and request for leave remain pending. Stay tuned for pertinent updates.

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Last month the Sixth District issued a written opinion requiring “pro se filer” Jaime Davidson (“Davidson”) to show cause why sanctions should not be imposed based on Davidson’s failure to comply with newly amended Florida Rule of General Practice and Judicial Procedure 2.515. Specifically, Davidson’s initial brief inaccurately cited legal authorities or cited “non-existent legal authorities” in violation of rule 2.515(d)(2). Davidson v. Chang-Warner, 2026 Fla. App. LEXIS 4936 (Fla. 6fh DCA June 26, 2026).
Although Davidson filed the initial brief about nine months before the amendments to rule 2.515(d)(2) became effective, the Court reasoned that application of the rule as amended was not retrospective “because the requirements and sanctions authority of the amended rule are consisted with those that pre-exited the amended rule.”
Notably, the Court provided Davidson until July 6, 2026, to respond to its show cause order. Davidson responded on the deadline by moving to withdraw the non-compliant brief and by seeking leave to file a “corrected” brief. To date, the show cause order and request for leave remain pending. Stay tuned for pertinent updates.

i You can read more about the amendments to rule 2.515 in last month’s eBlast entitled “Florida Supreme Court Amends Administrative Rules to Address “Hallucinated” Cases in Court Filings.”

ii The amendments to rule 2.515 took effect on June 15, 2026. In re Amends. to Fla. R. Gen. Prac. & Jud. Admin. 2.515, No. SC2026-0673, 2026 LX 282808 (May 28, 2026).

iii The Court acknowledged that the general rule was that amendments to procedural rules had prospective application “unless [the rule] specifically provided otherwise.”Davidson, at *5.

iv Davidson, at *5.

v Davidson, at *1-2

vi Davidson, at *3 (citing and quoting Dodd v. Fla. Bar, 118 So. 2d 17, 19 (Fla. 1960)).

vii Davidson, at *4 (quoting Cox v. Burke, 706 So. 2d 43, 47 (Fla. 5th DCA 1998)).

viii Davidson, at *4

ix Davidson, at *1.

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