United States v. Brewer
U.S. District Court, Middle District of Florida, Orlando Division · M.D. Fla. · Florida bar guidance
Verified May 5, 2026
- Citation
- United States v. Brewer, No. 6:19-cr-22-RBD-DCI, 2025 WL 2636404 (M.D. Fla. Sept. 11, 2025)
- Decided
- September 11, 2025
Summary
Defense attorney Bryan Savy filed a twelve-page motion to compel discovery in revocation proceedings before Judge Roy B. Dalton, Jr. The court found that nearly every case citation in the motion was incomplete, inaccurate, or fabricated, including two entirely invented decisions (United States v. Noel and United States v. Hernandez), several real cases quoted with language that did not appear in them, and United States v. Mmahat, 106 F.3d 89 (5th Cir. 1997), cited without disclosing that it had been abrogated and which in any event had nothing to do with the proposition for which it was offered. The court characterized the defects as "typical of AI hallucinations."
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The court denied the motion and ordered Savy to personally appear on October 2, 2025, to show cause why sanctions should not be imposed, including fines, suspension from the bar of the Middle District of Florida, referral to the district's Grievance Committee, referral to the Florida Bar, and any other sanctions available under the court's inherent powers. The order identified apparent violations of Local Rules 2.01(b)(2)(c), 2.01(e), and 3.01(a), and Florida Bar Rules 4-1.1, 4-1.6, 4-3.1, 4-3.3, and 4-8.4.
Why does United States v. Brewer matter for law firms using AI?
Brewer is a useful teaching case because the hallucinated authorities were not all obvious fabrications. Alongside two fully invented decisions, the motion cited real cases for propositions they do not support and quoted language that does not appear in them, and it cited United States v. Mmahat without flagging that the decision had been abrogated. For a managing partner, the case illustrates that an AI-assisted citation check has to verify both the existence of a case and its current subsequent history, not merely confirm that a reporter cite resolves.
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.