The Doc App, Inc. d/b/a My Florida Green v. Leafwell, Inc.
U.S. District Court, Middle District of Florida, Fort Myers Division · M.D. Fla. · Florida bar guidance
Verified May 5, 2026
- Citation
- The Doc App, Inc. v. Leafwell, Inc., No. 2:25-cv-838-SPC-NPM (M.D. Fla. Nov. 26, 2025)
- Decided
- November 26, 2025
Summary
Plaintiff's counsel Jason Castro filed a Motion for Temporary Restraining Order containing two completely fabricated case citations, four purported quotations that did not appear in the cited cases, and six citations supporting propositions the cases did not address. Judge Sheri Polster Chappell confirmed that Henson v. Allison Transmission, Inc., 2017 WL 59085 (M.D. Fla.) does not exist, and that a cited Florida appellate opinion was off by reporter, court, and year. After Mr. Castro denied misconduct and refused to confirm or deny use of AI in drafting, the court found his explanations not credible and concluded his "reckless use of AI" best explained the volume of misrepresentations.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Court ordered Castro to pay defense counsel's attorneys' fees and costs incurred responding to the Motion for TRO (amount to be determined by joint or separate notice due Dec. 22, 2025), to attend an in-person Florida CLE on legal ethics and AI by January 30, 2026, to attach the order to any complaint or notice of removal he files in the Middle District of Florida for two years, and to deliver the order to his client's CEO with a notarized confirmation affidavit. Castro was referred to the Florida Bar for discipline and the Clerk was directed to transmit the entire record.
Why does The Doc App, Inc. d/b/a My Florida Green v. Leafwell, Inc. matter for law firms using AI?
This sanctions order is notable for a Florida federal judge inferring AI use from the pattern of fabricated and miscited authority even though the sanctioned attorney never admitted to using a generative tool, and for layering forward-looking deterrents (mandatory AI ethics CLE, two-year order-attachment requirement, bar referral) on top of fee-shifting. For managing partners, the order illustrates that voluntary dismissal does not extinguish Rule 11 exposure once a show-cause order has issued, and that a defiant response to a show-cause order can convert a fee award into bar discipline.
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.