Florida Lawyer Blasted for Not Signing Own AI-Gaffe Apology

A Florida lawyer is being referred to ethics officials for possible sanctions after using inaccurate artificial intelligence-generated citations in a brief, and then having another member of her legal team submit the apology response on her behalf.

“While a delegated signature execution may not have been a legal or ethical impropriety, under these circumstances, it certainly didn’t make a good impression,” Florida Second District Court of Appeal Chief Judge Matthew C. Lucas said in a unanimous opinion referring attorney Sara Evelyn McLane to The Florida Bar.

“In the future, our orders to show cause for these kinds of matters will specify that counsel must personally execute the written response, though that point really should not need to be stated,” the court said.

The decision came in a case reviving a plaintiff’s pro se lawsuit against her deceased aunt’s former caregiver—represented by McLane—who become the personal representative of the aunt’s estate.

After saying the plaintiff could file an amended complaint, Lucas’ decision bemoaned the continued prevalence of generative AI blunders making their way into briefing.He cited an August order referring a lawyer to bar officials after he had AI write his brief and failed to check the computer’s work—an error the lawyer blamed on not checking a contract-paralegal’s use of AI.

McLane’s infraction was similar, filing filed an answer brief containing only three legal citations, all of which were inaccurate. Two contained inaccurate quotes from cases, while and a third cited a case that didn’t exist. Instead, the pages of the regional case law reporter cited in her brief dealt with a “criminal contempt proceeding against a member of the Florida House of Representatives who had refused to answer questions before a grand jury,” Lucas said, rather than a case highlighting a motion to dismiss standard McLane was leaning on.

Lucas said that McLane, an attorney at a family firm in Largo, Fla., admitted the citations “were researched via computer generated searches” and that she had “failed to fully vet these searches.”

The judge criticized her response and said the issue was more grave than she was characterizing it.

“But what counsel seems to imply—that since the substance of the analysis in her brief wasn’t necessarily wrong, her misstatements are not an issue we should be overly concerned about—is simply unacceptable. Indeed, we are deeply troubled by this brief and by this attorney’s response,” Lucas said.

Judges Robert Morris and Susan H. Rothstein-Youakim also heard the case.

The case is Russell v. Mells, Fla. Dist. Ct. App., 2d Dist., No. 2D2024-1560, 12/10/25.