Manisero v. Bradshaw
U.S. District Court, Southern District of Florida · S.D. Fla. · Florida bar guidance
Conduct
Here the defendant's reply said several of the pro se plaintiff's case citations were incorrect and implied AI use; the court made no finding on the citations.
Consequence
Here the court put the plaintiff on notice to supervise any AI and ensure no hallucinated citations or quotations, or it would consider sanctions.
Lesson
Here the court addressed possible AI use conditionally in its decretal paragraphs, without deciding whether AI was used.
Verified September 29, 2026
- Citation
- Manisero v. Bradshaw, No. 9:25-cv-80650-WM, Order Granting in Part and Denying in Part Defendant Sheriff Ric L. Bradshaw's Motion to Dismiss Third Amended Verified Complaint (S.D. Fla. Oct. 15, 2025) (Matthewman, M.J.), ECF No. 53
- Decided
- October 15, 2025
Summary
Matthew Nicholas Manisero sued Palm Beach County Sheriff Ric L. Bradshaw and others over his arrest and detention following a traffic collision. Ruling on the sheriff's motion to dismiss the third amended complaint, Chief Magistrate Judge William Matthewman summarized the sheriff's reply, which "points out that several of Plaintiff's case citations are incorrect, which implies the inappropriate use of Artificial Intelligence ("AI")." The order does not identify the citations or make its own finding about them.
- AI tool:
- Not found (the sheriff's reply said several of the plaintiff's case citations were incorrect, "which implies the inappropriate use of Artificial Intelligence"; the court made no finding and addressed its notice "[t]o the extent that Plaintiff is using AI"; no tool is named)
What did the court warn about?
The court granted the motion in part, dismissing two counts with prejudice and four without prejudice, with leave to file a fourth amended complaint by October 31, 2025. In its decretal paragraphs it added: "To the extent that Plaintiff is using AI to aid him in drafting his filings, Plaintiff is hereby put on notice that he is required to supervise the AI and ensure that there are no hallucinated citations or quotations in his papers. If Plaintiff fails to meet this obligation, the Court will consider imposing sanctions upon him." No sanction was imposed. A companion order on the City of Boca Raton's motion to dismiss (ECF No. 54) does not address AI.
Why does Manisero v. Bradshaw matter for law firms using AI?
Manisero v. Bradshaw is a motion to dismiss ruling in a civil rights case brought by a self-represented plaintiff. The AI issue came from the defendant: the sheriff’s reply pointed out that several of the plaintiff’s case citations were incorrect and said that implied inappropriate use of AI. The court’s order summarizes that point but does not identify the citations or decide whether AI was used.
Instead, the court added a conditional notice to its decretal paragraphs. To the extent the plaintiff uses AI in drafting, he “is required to supervise the AI and ensure that there are no hallucinated citations or quotations in his papers,” and if he does not, “the Court will consider imposing sanctions upon him.” On the merits, the same order dismissed two counts with prejudice and gave leave to amend the rest.
Firms documenting compliance may wish to consider that, here, the court framed AI supervision as the filer’s obligation without making any finding about the filing before it.
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.
- Raise incorrect citations in a reply with specifics. Here the defendant's reply flagged them, and the court responded with a notice to the filer even though it made no finding of its own.
- Supervise any AI used in drafting and check each citation and quotation. Here the court described that as an obligation of the filer, backed by possible sanctions.
Sources
Primary sources
- AI attribution: the order makes no finding that the plaintiff used AI or that any citation was fabricated; it summarizes the sheriff's reply and gives a conditional notice.
- Pro se status: the order does not say the plaintiff is pro se; a later court order on the CourtListener docket refers to 'the pro se Plaintiff,' and he filed papers in his own name.