Source: Bloomberg Law

A federal appeals court sharply criticized Anthony F. Sabatini, an attorney and Lake County, Fla. commissioner who until recently ran for Congress, for filing multiple briefs that a judge characterized as “replete with fake and hallucinated citations.” Judge Britt C. Grant wrote that Sabatini’s opening brief included at least eight case citations hallucinated by artificial intelligence and that, after Atlas Air pointed out errors, Sabatini withdrew eight additional citations that were also fake; the decision was authored by Grant for a unanimous three-judge panel.

The opinion said that outsourcing legal work to an AI algorithm violated the attorney’s ethical duties to clients and to the court and noted that the matter will be referred to the Court’s Committee on Lawyer Qualifications and Conduct. On the merits, the Eleventh Circuit affirmed dismissal of the employees’ claims against Atlas Air, holding the workers failed to prove animosity toward their religious beliefs or a hostile-work-environment under Title VII, found their objections to masking and testing were largely political and logistical rather than religious, and rejected related constitutional, food-and-drug-safety, and state tort and privacy claims.