What happened

On July 10, 2026, the U.S. Court of Appeals for the Eleventh Circuit affirmed the dismissal of a lawsuit brought by aviation employees challenging pandemic-era workplace policies. The court then devoted the end of its published opinion to the conduct of plaintiffs’ counsel Anthony F. Sabatini.

According to the opinion, the opening brief relied on at least eight nonexistent cases. After the defendants flagged the problem, counsel submitted a proposed reply acknowledging eight “erroneous or unverifiable” citations and attempted to withdraw them.

Those were not the same eight citations the defendants had identified. The court found that the second list was also made up.

What crossed the boundary

AI-assisted research became a signed court filing without the basic verification that the cited cases existed. When the failure was identified, a second unverified list was submitted as the correction.

The court described the work as outsourced to an AI algorithm, but the opinion does not identify the product or model. Naming a specific chatbot would go beyond the record.

What went sideways

The appeal failed on its legal merits independently of the citation problem. The court affirmed dismissal for lack of personal jurisdiction and failure to state a claim.

The citation failures created an additional consequence: the court said the matter would be referred to its Committee on Lawyer Qualifications and Conduct. A referral is not the same as a final disciplinary finding, and the published opinion does not report a completed sanction proceeding.

What the evidence supports

The court’s opinion directly documents the nonexistent authorities, the attempted withdrawal, and the announced referral. It also makes clear that the underlying claims were dismissed for substantive and jurisdictional reasons, not simply because AI was used.

The practical lesson

A fluent citation is not a citation. In a profession built around checkable authority, opening the cited case is the smallest possible verification step—and signing a filing makes the human responsible for what the machine supplied.