In re Thomas Grant Neusom
U.S. District Court, Middle District of Florida · M.D. Fla. · Florida bar guidance
Verified May 14, 2026
- Citation
- In re Thomas Grant Neusom, No. 2:24-mc-00002-JES (M.D. Fla. Mar. 8, 2024)
- Decided
- March 8, 2024
Summary
Attorney Thomas Grant Neusom filed pleadings in Clark Pear LLC v. MVP Realty Associates LLC, No. 2:23-cv-00503 (M.D. Fla.), that contained fabricated case citations supporting frivolous legal arguments. When opposing counsel could not locate the cited authorities and asked for copies, Neusom gave non-responsive answers. Before the court's grievance committee, Neusom acknowledged using Westlaw and Fastcase and stated he "may have used artificial intelligence to draft the filing(s)" but did not verify the excerpts and citations before filing. The grievance committee found his conduct went beyond a lack of due diligence because some authorities were "completely fabricated."
- AI tool:
- Unspecified (attorney admitted he 'may have used artificial intelligence')
What sanction did the court impose?
One-year suspension from the Bar of the U.S. District Court for the Middle District of Florida, effective 30 days from the order, with prohibition on taking new federal cases until reinstatement. The Florida Supreme Court imposed reciprocal discipline on January 16, 2025 (Fla. Bar v. Neusom, No. SC2024-0611), and the Southern District of Florida followed with reciprocal suspension on May 6, 2025 (Admin. Order 2025-29).
Why does In re Thomas Grant Neusom matter for law firms using AI?
In re Neusom is one of only a handful of cases in which a federal court has suspended an attorney from its bar for filing AI-generated fabricated citations, distinguishing it from the more common monetary-sanction cases like Mata v. Avianca. The discipline cascaded: the Florida Supreme Court imposed reciprocal discipline in January 2025, and the Southern District of Florida followed in May 2025 after Neusom failed to respond to its show-cause order. For firms tracking AI governance risk, the case illustrates that a single failure to verify citations can produce parallel federal-bar, state-bar, and reciprocal federal-bar discipline.