Innocent v. Meraki Installers, LLC
District Court of Appeal of the State of Florida, Fourth District · Fla. 4th DCA · Florida bar guidance
Conduct
Appellants' initial brief contained quotations from the trial transcript that, the court said, do not appear to be found anywhere in the transcript or the record.
Consequence
Judgment affirmed; the Fourth DCA referred the matter to The Florida Bar for appropriate action. No fine or fee award.
Lesson
Here, transcript quotations that could not be found in the record led to a Bar referral; quotations from a transcript can be checked against the transcript itself.
Verified September 28, 2026
- Citation
- Innocent v. Meraki Installers, LLC, No. 4D2025-1151 (Fla. 4th DCA May 27, 2026) (per curiam)
- Decided
- May 27, 2026
Summary
Thomas and Roselene A. Innocent appealed a final judgment entered for Meraki Installers, LLC in a St. Lucie County lawsuit for breach of contract and foreclosure of a construction lien. They were represented on appeal by counsel; the opinion does not name the lawyer whose conduct is referred. The Fourth District affirmed without comment on all issues but wrote "briefly [...] to address concerns regarding multiple quotations from the trial transcript contained in Appellant's initial brief that do not appear to be found anywhere in the actual trial transcript or otherwise in the Record." The court wrote "[i]n consideration of the arguments made on this point in the parties' briefs, as well as during oral argument." The opinion does not describe the quotations individually, say how they came to be in the brief, or mention artificial intelligence. For authority, it cites the same court's same-day decision in Eclectic Synergy, LLC v. Seredin, No. 4D26-0781, and, through it, the Second District's statement in Russell v. Mells that "[w]hen a lawyer cites imaginary legal authorities to our court as if they were law, we are compelled to refer that lawyer to the Bar," along with Canon 3D(2) of the Florida Code of Judicial Conduct and Rule Regulating The Florida Bar 3-7.18(a)(2).
- AI tool:
- Unidentified (the opinion flags trial-transcript quotations that do not appear in the record but does not mention AI or name a tool)
- Amount or terms:
- No monetary sanction; matter referred to The Florida Bar for appropriate action
How did the court address the AI-related conduct?
The final judgment for Meraki Installers was affirmed. "In consideration of the arguments made on this point in the parties' briefs, as well as during oral argument," the per curiam panel (Kuntz, C.J., and Levine and Shaw, JJ.) referred the matter to The Florida Bar "for appropriate action." The opinion does not name the lawyer whose conduct is referred, does not describe the referral as a sanction, and imposes no fine, fee award, or other sanction. It does not make a finding about how the quotations were produced; its language is that the quotations "do not appear to be found" in the transcript or record. Canon 3D(2), which the court quotes, directs a judge with information that a lawyer has likely violated the Bar rules to "take appropriate action," and Rule 3-7.18(a)(2) governs judicial referrals to the Bar. The opinion is marked not final until disposition of any timely motion for rehearing.
Why does Innocent v. Meraki Installers, LLC matter for law firms using AI?
Innocent v. Meraki Installers applies the Fourth District’s Bar-referral practice to a brief’s quotations from the trial record rather than to its case citations. The appeal itself was routine: the court affirmed the construction-lien judgment “without comment on all issues.” It wrote only to address “multiple quotations from the trial transcript contained in Appellant’s initial brief that do not appear to be found anywhere in the actual trial transcript or otherwise in the Record,” a point the parties had argued in their briefs and at oral argument.
The opinion is short and careful about what it finds. It does not quote the offending passages, attribute them to artificial intelligence, or identify the lawyer responsible, and its operative language is that the quotations “do not appear to be found” in the record. Its authority is borrowed. It cites the same court’s same-day Eclectic Synergy, LLC v. Seredin decision, and through it the Second District’s Russell v. Mells rule that a lawyer who “cites imaginary legal authorities to our court as if they were law” must be referred to the Bar, together with the Code of Judicial Conduct canon that requires a judge to “take appropriate action” on information of a likely Bar-rule violation.
For firms, the practical point is that citation-verification processes built around case law do not catch this failure. Quotations attributed to a trial transcript are verified only by reading the transcript at the cited page. Firms documenting compliance may wish to consider whether their pre-filing review covers record citations and quotations as well as authorities.
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.
- Verify every quotation from a transcript or record against the record itself before filing. The court treated quotations not found in the trial transcript as warranting a Bar referral, citing a decision about imaginary legal authorities.
- Review record-cite checking as a separate step from case-cite checking. The defect here was in the statement of the record, which ordinary citator checks do not reach.
- Consider that a brief-quality issue argued in the parties' briefs and at oral argument can produce a referral even when the appeal is decided on the merits without comment.
Sources
Primary sources
- AI attribution is a Charlotin tracker inference ('Implied'). The opinion flags quotations from the trial transcript that do not appear in the record but does not mention artificial intelligence or say how the quotations were produced.