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De Ford v. Koutoulas

U.S. District Court, Middle District of Florida (Orlando Division) · M.D. Fla. · Florida bar guidance

Court sanction

Verified April 26, 2026

Citation
De Ford v. Koutoulas, No. 6:22-cv-00652-PGB-DCI (M.D. Fla. Dec. 2, 2025)
Decided
December 2, 2025

Summary

In a putative securities class action against James Koutoulas and LGBCoin, LTD concerning the "Let's Go Brandon" meme cryptocurrency, counsel submitted a brief relying on a purported supporting opinion that the court determined did not exist. The court treated the citation as a fabricated, AI-generated reference and addressed the defective filing through a warning rather than monetary sanctions. The case is captioned De Ford, Bader, and Key v. Koutoulas, No. 6:22-cv-00652 (M.D. Fla.).

AI tool:
Unspecified generative AI
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

The court issued a warning to counsel concerning the fabricated citation. No monetary sanction was imposed in the December 2, 2025 order. The identity of the specific attorney warned and any further conditions are recorded in the order itself.

Why does De Ford v. Koutoulas matter for law firms using AI?

De Ford v. Koutoulas illustrates that AI hallucination problems are now appearing in substantive securities class actions, not just small or pro se matters. For a 5-50 attorney firm taking on complex commercial work, the practical lesson is that even routine briefing on a long-running docket needs a citation-verification step before filing. A warning here, rather than fees, reflects judicial discretion the next attorney in the same posture should not assume will be repeated.

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Sanctions cases

From the blog

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.

Unverified claims:
  • Specific name of the sanctioned attorney and firm could not be extracted from the Charlotin PDF (binary content not text-readable to verifier) and was not located in a primary-source secondary write-up.
  • Specific text and caption of the fabricated "meme coin" supporting opinion could not be quoted from the order.
  • Whether the AI tool was named in the order, or only inferred from the nature of the fabrication.