Robbins v. Martin Law Firm, P.L.
U.S. District Court, Middle District of Florida, Fort Myers Division · M.D. Fla. · Florida bar guidance
Verified April 26, 2026
- Citation
- Robbins v. Martin, No. 2:25-cv-409-JES-NPM (M.D. Fla. July 28, 2025)
- Decided
- July 28, 2025
Summary
Plaintiff's counsel Tesha Allison filed a motion to remand citing multiple fabricated or misquoted authorities, including a nonexistent Baker v. BDO Seidman, LLP citation (No. 6:15-cv-1220-Orl-37GJK, 2015 WL 5009340) and invented direct quotations attributed to In re Republic Reader's Service, Eastus v. Blue Bell Creameries, and Hirsch v. Arthur Andersen. Counsel also misrepresented the holding of Kircher v. Putnam Funds Trust. In response to the show-cause order, Allison conceded the citations were incorrect, attributed the errors to health issues and "limited outside assistance with legal research," and asked the court to "grant grace in lieu of sanctions." Senior Judge John E. Steele found counsel had failed to make a reasonable inquiry into the validity of the citations.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanctions imposed. The court declined to sanction under Rule 11 (defendants did not comply with the 21-day safe harbor), 28 U.S.C. section 1927 (no showing of objective bad faith), or its inherent powers (no showing of subjective bad faith). The court issued a formal warning to attorney Tesha Allison, Florida Bar No. 108538, that "any other similar incident in ANY case before this Court will not be viewed with such leniency."
Why does Robbins v. Martin Law Firm, P.L. matter for law firms using AI?
Robbins illustrates how the Rule 11 safe-harbor provision can shield counsel from monetary sanctions even where fabricated citations are conceded, while still producing a docketed judicial warning that follows the attorney into future matters. For managing partners, the case is a reminder that the absence of a fee award is not the absence of professional risk: a named warning from a federal judge is itself a malpractice and bar-discipline exposure that a firm’s AI use policy should be designed to prevent.
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.