The sanctions record · United States, Eleventh Circuit, 2026

Marion Parnell Jr. v. Florida Department of Corrections

No. 25-11166 · United States Court of Appeals for the Eleventh Circuit · for publication · 181 F.4th 1209 · 10 July 2026

Page verified 30 August 2026. Published Eleventh Circuit authority, read in full from the court’s own opinion. It is out of the current watch window and is recorded here because two later decisions rely on it.

Published, and therefore binding within the circuit. Two non-existent opinions and at least five non-existent quotations from the Eleventh Circuit’s own decisions appeared in a reply brief. The merits were affirmed, portions of the reply brief were struck, fees for the motion to strike were granted with the amount reserved, and counsel was referred to the circuit’s Committee on Lawyer Qualifications and Conduct.

What the court refused to make relevant

“Whether counsel wrote the reply brief, relied on a non-lawyer for drafting, or used a notoriously unreliable generative AI platform, counsel’s signature verifies that his contentions ‘are warranted by existing law.’”

Three possible authors, one obligation. The court declines to make the method of production the question. The signature is the question.

On the response to being caught:

“We are disappointed with counsel’s lack of forthcoming candor.”

Counsel withdrew the statements and argued that the motion was moot and the errors not made in bad faith. That is the argument the sentence above answers.

The order

MeritsAffirmed.
StrikeGranted, as to portions of the reply brief.
FeesGranted for preparing the motion to strike. Jurisdiction reserved to fix the amount. A fee affidavit was due within ten days, with ten days to respond. The opinion states no figure, and neither do we.
ReferralCounsel referred to the Committee on Lawyer Qualifications and Conduct under Eleventh Circuit Rule, Addendum Eight, Rule 2.

Addendum Eight, Rule 1(B) sets out what that committee can reach: disbarment, suspension, reprimand, monetary sanctions, removal from Criminal Justice Act panels, and removal from the roster of attorneys admitted to practise before the court.

Two details worth keeping

First, the opinion cites Damien Charlotin’s tracker as its measure of the scale of the problem, describing it as listing over 1,000 judicial decisions dealing with AI hallucinations, by an archived link last visited 22 May 2026. A federal court of appeals treating a public compilation as the reference point is itself a fact about where this sits.

Second, a footnote records the Florida Supreme Court’s amendment of Rule 2.515(d)(2) of the Florida Rules of General Practice and Judicial Administration, In re Amendments, No. SC2026-0673, 2026 WL 1487646 (Fla. 28 May 2026). The signature rule and the AI question are being connected at state level too.

What this case contributes

The statusPublished Eleventh Circuit authority, not an unreported order. It is now cited by district courts within the circuit.
The frameAuthorship is not the issue. The signature is. That framing survives any argument about which tool was used.
The targetThe court’s own opinions were misquoted, at least five times. The forgery was of the court’s own words.
The remedyFees plus a referral to a committee that can reach removal from the roster.

The lesson for the next filing

If the signature is the obligation, then the question after the fact is always the same: what did the person who signed actually verify, and when.

That is answerable in one document if the record was made during the work, and is a matter of reconstruction and candour if it was not. This opinion is about what happens in the second case.

Generate the certification → · Read the full record →

Sources

Published opinion, No. 25-11166 (11th Cir. 10 July 2026), six pages, read in full.
Reported at 181 F.4th 1209. Per curiam, Non-Argument Calendar, on appeal from the Southern District of Florida.
Counsel is named in the published opinion and was referred by name. We repeat the court’s own record and add nothing to it.

The full sanctions record
James v. Conley, which relies on this opinion
Whiting v. City of Athens and Fletcher v. Experian, the other published federal appellate matters on this record
Capital Standard v. U.S. Bank, Florida, the same summer

Checked 30 August 2026 against the published opinion, read in full. Information, not legal advice.

Information, not legal advice. Every entry is verified against the court’s own document or contemporaneous reporting; where a source is reporting rather than the document, we say so.