Tesla awarded sanctions where opposing party cited AI-generated cases in discovery briefing

Plaintiff sued Tesla in federal court in the Southern District of Florida. During discovery, plaintiff filed multiple motions that cited fake case law hallucinated by artificial intelligence. Defendant moved to strike the filings and asked the court to award attorneys’ fees for the time spent addressing the fake citations and related motions.

Defendant argued that its attorneys spent more than five hours reviewing the false citations, drafting a motion to strike, and responding to a motion to compel contact information. Defendant requested $1,096 in fees. Plaintiff objected, claiming the hours were excessive and that defendant had not properly conferred before seeking fees. Plaintiff had offered to pay only one dollar as a “symbolic” resolution.

The court rejected plaintiff’s arguments. It found that plaintiff did not confer in good faith and was again wasting the court’s time. Although plaintiff was not a lawyer, the court held that pro se litigants must still follow the rules and act professionally. The court emphasized that submitting hallucinated cases, even unintentionally, undermines the judicial process.

The court reduced the requested amount slightly, finding that some billing entries were duplicative, as both attorneys reviewed the same documents. Plaintiff was ordered to pay the reduced amount and defendant was required to notify the court whether payment was received.

Crespo v. Tesla, Inc., 2025 WL 1921903 (S.D. Florida, July 11, 2025)