Cames v. Lowe's Home Centers, LLC

What did the court warn about?

The court denied Lowe's Amended Motion to Compel Arbitration and Stay Proceedings without prejudice, holding that Lowe's had not carried its initial burden to show a valid agreement to arbitrate as to Teresa Cames or that the three claims are arbitrable, and ordered Lowe's to respond to the complaint by July 31, 2026. On the citations, footnote 4 states: "To the extent this is merely another typo, the Court cautions counsel to be more attentive. But the typos paired with the misstatements of the holdings raises a suspicion of improper A.I. usage." Citing United States v. Brewer (M.D. Fla. Sept. 11, 2025) for the "hallmarks of A.I. hallucinations," the court "accordingly cautions counsel that submitting briefs with A.I. hallucinations may violate" a list of rules it quoted from Brewer: Local Rules 2.01(b)(2)(c), 2.01(e) and 3.01(a), and Florida Bar Rules 4-1.1, 4-1.6, 4-3.1, 4-3.3 and 4-8.4. The court made no finding that AI was used and imposed no sanction, show-cause order or referral. The order does not name Lowe's counsel.

Why does Cames v. Lowe's Home Centers, LLC matter for law firms using AI?

The court’s AI discussion sits in a footnote to a ruling that turned on the motion’s substantive gaps. The order found the arbitration motion “woefully insufficient”: Lowe’s addressed only Olaf Cames, who signed the contract, raised the non-signatory Teresa Cames only in reply, and offered a conclusory statement on arbitrability. In working through the non-signatory question, the court checked Lowe’s authorities and found that Shetty has no page 625, that Kroma ends two pages before the cited pinpoint, and that both cases address the opposite question from the one Lowe’s cited them for.

The court was careful about what it concluded from that. It allowed for the possibility that the Kroma pinpoint was “merely another typo,” and to that extent cautioned counsel “to be more attentive.” It then said “the typos paired with the misstatements of the holdings raises a suspicion of improper A.I. usage,” citing the same district’s Brewer decision for the hallmarks of hallucinated output, and cautioned that submitting briefs with AI hallucinations “may violate” listed Local Rules and Florida Bar rules. That is a caution, not a finding or a sanction.

Firms documenting compliance may wish to consider that the defects here were pinpoint and characterization errors, not invented cases, and the court still connected them to possible AI use. The court also drew a contrast with the other side: it noted that the pro se plaintiffs made the same slip-opinion citation error but saw “little reason” for represented counsel to do so.