Crespo v. Tesla, Inc.
U.S. District Court, Southern District of Florida · S.D. Fla. · Florida bar guidance
Conduct
Pro se plaintiff filed discovery motions citing non-existent and misquoted authority that the court determined was AI-generated.
Consequence
OSC and Second Order denying discovery motions, followed by a July 11, 2025 order awarding attorneys' fees to Tesla.
Lesson
S.D. Fla. Matthewman: pro se status doesn't insulate against fee-shifting; court verifies citations sua sponte.
Verified May 14, 2026
- Citation
- Crespo v. Tesla, Inc., No. 9:25-cv-80129 (S.D. Fla. Jul. 11, 2025) (Matthewman, M.J.)
- Decided
- July 11, 2025
Summary
Pro se plaintiff Leonardo Crespo cited authority in motions and replies on discovery that the court determined to be nonexistent or misquoted, including "Perez v. Miami-Dade Cnty., 297 F.R.D. 620, 625 (S.D. Fla. 2013)" and "Jacobs v. Atrium Med. Corp., 2020 WL 5803503." Magistrate Judge William Matthewman issued an Order to Show Cause on June 18, 2025 asking Crespo to explain the citations and whether he had used AI. On June 30, 2025, Matthewman issued the "Second Order on Discovery Motions and on the Submission of Fake, Hallucinated Cases by the Pro Se Plaintiff Leonardo Crespo," denying the underlying discovery motions (reported at 2025 WL 1799411).
- AI tool:
- Generative AI (plaintiff used AI to generate discovery motions per the docketed Order to Show Cause; specific tool not named on the docket text we have)
What sanction did the court impose?
Order Awarding Attorneys' Fees to Defendant Tesla, Inc., signed July 11, 2025, granting in part and denying in part Tesla's fee motion. Specifics of the remedy package (any non-monetary conditions, the precise reduction applied) are in the order text not pulled into this entry.
Why does Crespo v. Tesla, Inc. matter for law firms using AI?
Crespo v. Tesla is the S.D. Fla.’s pro se AI-citation sanctions matter from chambers 2303. The docket sequence is the load-bearing record: Magistrate Judge Matthewman issued an Order to Show Cause sua sponte on June 18, 2025 after independently checking citations in Crespo’s discovery motions and replies and finding “Perez v. Miami-Dade Cnty.” and “Jacobs v. Atrium Med. Corp.” appeared to be nonexistent and a quote from Universal City Dev. Partners did not exist in that case. Matthewman’s June 30, 2025 order (reported at 2025 WL 1799411) denied the affected discovery motions and was titled “Second Order on Discovery Motions and on the Submission of Fake, Hallucinated Cases by the Pro Se Plaintiff Leonardo Crespo.” On July 11, 2025, the court entered an order awarding attorneys’ fees to Tesla, granting in part and denying in part Tesla’s fee motion.
For institutional defendants in S.D. Fla. facing pro se opposition that cites suspect authority, the docket here is a roadmap: the court will independently verify cited cases, an OSC is the procedural vehicle for compelling an answer about AI use, and fee-shifting is on the table even against a self-represented party. The exact remedy calibration and the court’s quoted language on candor and judicial process are reported by aggregator coverage but, in this entry, are flagged as unverified pending PACER or RECAP access to the underlying order PDFs. Specific docket entry numbers are likewise treated as unverified given inconsistencies between aggregator-derived numbering and the primary order text.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Pro se status is not protective. The court treated the pro se plaintiff under the same verification standard as represented parties and entered fee-shifting against him. Firms defending institutional clients against pro se AI-fabricated citations have authority for a fee-shifting motion in this district.
- Matthewman acts sua sponte on suspect citations. The Order to Show Cause was triggered by the court's own check of cited authority, not by an opposing motion. Counsel in chambers 2303 should assume any cited case will be independently verified by the court.
- Matthewman has a chambers pattern. He has issued a separate sanctions order in Versant Funding v. Teras Breakbulk (May 20, 2025; attorneys Lord and Bello). The two orders are different cases but reflect consistent enforcement against AI-citation failures regardless of pro se or represented status.
Sources
Primary sources
Further reading
- The final dollar amount of the July 11, 2025 fee award is not fixed in the Second Order on Discovery Motions (the canonical text reviewed here); that order sets a fee-briefing schedule and leaves the amount to be determined. The separate July 11, 2025 fee award order has not been reviewed directly.