Arch Insurance Company v. A3 Development, LLC
U.S. District Court, Southern District of Florida · S.D. Fla. · Florida bar guidance
Verified May 5, 2026
- Citation
- Arch Insurance Co. v. A3 Development, LLC, No. 23-cv-23524-BLOOM/Torres, 2025 WL 3091075 (S.D. Fla. Oct. 21, 2025)
- Decided
- October 21, 2025
Summary
Defense attorneys Michael Kurzman and Elizabeth Coppolecchia of Weiss Serota Helfman Cole and Bierman submitted a response brief opposing a motion to strike affirmative defenses that cited at least two non-existent cases, including Solis v. Zenith Cap., LLC, 2019 WL 7376782, and PGA National Resort, LLC v. Liberty Mutual Fire Insurance Co., 2016 WL 8716673. Judge Beth Bloom flagged the fabricated citations in a footnote to her order resolving the underlying motion and required counsel to show cause why Rule 11 sanctions should not issue.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to Show Cause issued. The court directed Kurzman and Coppolecchia to show cause by October 28, 2025 why Rule 11 sanctions should not be imposed for providing the court with non-existent cases. No monetary sanctions were imposed in this order.
Why does Arch Insurance Company v. A3 Development, LLC matter for law firms using AI?
Arch Insurance illustrates how AI-assisted citation errors are surfacing in routine commercial litigation, not just in pro se filings. The court caught the fabricated authorities while ruling on an ordinary motion to strike affirmative defenses, and explicitly invoked Mata v. Avianca and the recent ByoPlanet decision in framing the duty of candor. For managing partners, the case underscores that even brief, secondary filings such as oppositions to motions to strike warrant the same citation-verification discipline as dispositive briefing.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.