Bey v. Glass
U.S. District Court, Middle District of Florida · M.D. Fla. · Florida bar guidance
Verified May 14, 2026
- Citation
- Bey v. Glass, No. 8:25-cv-01977-WFJ-CPT, 2025 WL 3442739 (M.D. Fla. Dec. 1, 2025) (Jung, J.)
- Decided
- December 1, 2025
Summary
Ali Bey, proceeding pro se, sued nine defendants in the Middle District of Florida in a collateral attack on his Florida felony conviction. By the time the court reached the motions to dismiss, only Count V remained, against the Commissioner of the Florida Department of Law Enforcement and the Hillsborough County Clerk. In a footnote, Judge William Jung flagged a citation in Bey's complaint, "Ford v. Browning, 568 F.3d 1175 (11th Cir. 2009)," that the court could not locate. The court believed it "a hallucination, possibly caused by the use of Artificial Intelligence during the drafting of the Complaint."
- AI tool:
- Unidentified (the court believed a fabricated citation was 'possibly caused by the use of Artificial Intelligence'; no tool named)
What sanction did the court impose?
The court granted the motions to dismiss and closed the case, abstaining from Count V under Younger v. Harris because Bey's requested declaratory and injunctive relief would interfere with his ongoing state criminal proceeding. The court imposed no sanction for the fabricated citation. In the same footnote, it warned Bey that it had "inherent authority under Federal Rule of Civil Procedure 11 to sanction Plaintiff for such conduct, including the complete dismissal and termination of the case."
Why does Bey v. Glass matter for law firms using AI?
Bey v. Glass is a study in how a single fabricated citation surfaces even in a case the court resolves on other grounds. Judge Jung dismissed the surviving count under Younger abstention, a federalism doctrine that keeps federal courts out of pending state criminal matters, and never reached the merits. The AI-hallucinated citation appears only in a footnote, attached to an argument the court had already set aside. The court still flagged it, still named Rule 11, and still warned that the sanction available for the conduct ran as far as dismissal of the entire case.
For a firm screening pro se filings, the operational point is that a court will catch and call out a fabricated citation regardless of whether it changed the outcome. The footnote treatment here is not leniency. It is a documented warning that converts the next fabrication in this litigant’s filings into sanctionable conduct on an already-built record.