{"schema_version":"0.10.0","id":"LR-2026-0655","record_version":1,"title":"Federal appeals court refers Anthony Sabatini over AI-faked citations","verification":{"human_verified":false,"method":"automated_gate","auto_verified":true,"score":42.0,"score_breakdown":{"source_authority":12.1,"independent_corroboration":7.0,"implicated_party_confirmed":0.0,"citation_integrity":14.0,"specificity":0.0,"completeness":2.24,"unhedged_language":4.55},"checks":{"schema_valid":true,"every_field_cited":true,"quotes_verbatim":true,"source_fetched":true,"distinct_incident":true,"dates_plausible":true,"sources_agree":true,"source_describes_incident":true,"severe_backed_by_source":true,"record_integrity":true,"eligible":true,"about_this_case":true},"gate_version":"gate-2026-10-18.7","cross_check_model":null,"cross_check_agreement":null,"duplicate_of":null,"verified_by":null,"verified_at":"2026-11-01","extraction_run_id":null,"evidence_level":{"level":"preliminary","reason":"Publisher not yet named · subject to change","original_document":null,"reports_total":1,"reports_independent":0,"reports_derivative":0,"developing":false,"disputed":false,"rules_version":"evidence-2026-10-29.1","computed_at":"2026-11-01","history":[{"date":"2026-11-01","from_level":null,"to_level":"preliminary","reason":"Publisher not yet named · subject to change"}]},"sources_hash":"8b09fb9145325e69de8ad3556fb1f748d23ac22f2b9b01da6e92307d3e79a033"},"system":{"model_name":null,"model_version":null,"developer":"unknown","harness":null,"tools_granted":[],"permissions_scope":null,"autonomy_level":"unknown","guardrails_present":[],"deployment_context":"unknown","tier":null,"lifecycle_stage":null,"integration_type":null,"intended_use":null,"safeguard_state":null,"production_intended":null},"event":{"date_occurred":null,"date_disclosed":"2026-07-10","incident_class":"hallucination","failure_class":null,"agent_involved":null,"secondary_failure_classes":[],"trigger":"unknown","duration":null,"detection_method":"third_party","summary":"A lawyer, Anthony Sabatini, filed appellate briefs in a pandemic-era lawsuit brought by aviation workers against Atlas Air and Flight Services International over COVID vaccine, testing and mask policies. The 11th U.S. Circuit Court of Appeals found the briefs contained fabricated case citations: the opening brief relied on at least eight nonexistent cases. After opposing counsel flagged the problem, Sabatini filed an untimely reply acknowledging the citations were erroneous or unverifiable and sought to withdraw eight cases. The withdrawn cases did not match the hallucinated ones, and all eight were also hallucinated. The court referred him to its Committee on Lawyer Qualifications and Conduct for possible discipline. Appellate costs were taxed against his clients.","tags":[],"date_detected":null,"near_miss":null,"root_cause":null,"root_cause_detail":null,"failure_class_detail":null,"responsible_party":null,"adversarial_actor":null,"input_provenance":null,"time_to_contain":null,"operations_paused":null,"remediation":null,"precursor_events":null},"impact":{"direct_loss_usd":null,"remediation_hours":null,"records_exposed":null,"third_parties_affected_count":null,"severity":"moderate","harm_class":[],"affected_description":null,"protected_class_involved":null,"data_categories_exposed":[],"loss_range_usd":null,"reversibility":null,"downstream_exposure_count":null},"evidence":{"sources":[{"url":"https://floridapolitics.com/archives/806892-no-substitute-for-actual-intelligence-federal-appeals-court-refers-anthony-sabatini-for-discipline-over-ai-faked-citations/","publisher":"Florida Politics","date":"2026-07-10","type":"press","title":"'No substitute for actual intelligence': Federal appeals court refers Anthony Sabatini for discipline over AI-faked citations - Florida Politics","archived_url":null,"attachment":"first_report"}],"per_field_confidence":{"event.incident_class":"C","event.detection_method":"C","context.country":"C","impact.severity":"D","event.summary":"C","system.autonomy_level":"D","system.deployment_context":"D","event.trigger":"D","system.developer":"D","event.date_disclosed":"D","context.denominator_available":"D"},"field_citations":{"event.incident_class":[{"source_index":0,"quote":"In a unanimous opinion, the 11th U.S. Circuit Court of Appeals said the Lake County Commissioner and former state Representative filed briefs “replete with fake and hallucinated citations” — and referred him to the court’s Committee on Lawyer Qualifications and Conduct for possible discipline."}],"event.detection_method":[{"source_index":0,"quote":"After opposing counsel flagged the problem, Sabatini filed an untimely reply acknowledging the citations were “erroneous or unverifiable” and sought to withdraw eight cases."}],"context.country":[{"source_index":0,"quote":"In a unanimous opinion, the 11th U.S. Circuit Court of Appeals said the Lake County Commissioner and former state Representative filed briefs “replete with fake and hallucinated citations” — and referred him to the court’s Committee on Lawyer Qualifications and Conduct for possible discipline."}],"impact.severity":[{"source_index":0,"quote":"Sabatini represented a group of aviation workers suing Atlas Air and Flight Services International over COVID vaccine, testing and mask policies."}],"event.summary":[{"source_index":0,"quote":"That lawyer is Anthony Sabatini."},{"source_index":0,"quote":"Sabatini represented a group of aviation workers suing Atlas Air and Flight Services International over COVID vaccine, testing and mask policies."},{"source_index":0,"quote":"Per the court, Sabatini’s opening brief relied on at least eight nonexistent cases — “including one purportedly decided by this Court.”"},{"source_index":0,"quote":"After opposing counsel flagged the problem, Sabatini filed an untimely reply acknowledging the citations were “erroneous or unverifiable” and sought to withdraw eight cases."},{"source_index":0,"quote":"The eight cases Sabatini ‘withdrew’ did not match a single one of the eight hallucinated cases in his opening brief."},{"source_index":0,"quote":"The referral to the court’s lawyer-conduct committee comes by separate order through the Chief Judge."},{"source_index":0,"quote":"Appellate costs were taxed against Sabatini’s clients."}]},"notes_on_gaps":"Single press source (Florida Politics); the court opinion itself was not provided. No opinion date, filing dates or sanctions amount are stated; the article date 2026-07-10 is used as date_disclosed (judgement, taken from the source header). The AI tool, product, developer and model are not named, so system fields are omitted. Event is a lawyer's use of AI tools, not an autonomous agent, so agent_involved is false and failure fields are omitted. Responsible party, root cause and trigger are not stated as such and are omitted. Control I7 outcome 'missing' is a judgement drawn from the court's statement that the lawyer did not check the output. Severity 'moderate' is a judgement: one bounded appeal, court and opposing party touched. The referral is a possible-discipline referral, not a finding of discipline. Country US is inferred from the 11th U.S. Circuit Court of Appeals; industry legal services is inferred from the legal work described. No remediation is reported in the sources. [case created by the backfill: read by claude-haiku-5-5, backfill-2026-11-01.2, 2026-11-01; not yet reviewed] [2026-11-01: evidence level set: Preliminary (Publisher not yet named · subject to change)]"},"context":{"industry":null,"org_size_band":null,"country":"US","denominator_available":false,"denominator":null,"related_incident_ids":[],"systemic_exposure":null,"shared_model_id":null,"upstream_incident_id":null,"incident_evidence":null,"regulatory":null,"coverage":null},"narrative":{"steps":[{"step":"went_wrong","text":"The opening brief relied on at least eight nonexistent cases.","quote":"Per the court, Sabatini’s opening brief relied on at least eight nonexistent cases — “including one purportedly decided by this Court.”","source_index":0,"grade":"C"},{"step":"caught","text":"Opposing counsel flagged the problem, and Sabatini's untimely reply admitted the citations were erroneous or unverifiable.","quote":"After opposing counsel flagged the problem, Sabatini filed an untimely reply acknowledging the citations were “erroneous or unverifiable” and sought to withdraw eight cases.","source_index":0,"grade":"C"}],"model":"claude-haiku-5-5","prompt_version":"backfill-2026-11-01.2","extracted_at":"2026-11-01","source_urls":["https://floridapolitics.com/archives/806892-no-substitute-for-actual-intelligence-federal-appeals-court-refers-anthony-sabatini-for-discipline-over-ai-faked-citations/"]},"analysis":{"sections":{"timeline":[{"text":"Opening brief filed relying on at least eight nonexistent cases.","quote":"Per the court, Sabatini’s opening brief relied on at least eight nonexistent cases — “including one purportedly decided by this Court.”","source_index":0,"when":null},{"text":"After opposing counsel flagged the problem, Sabatini filed an untimely reply seeking to withdraw eight cases.","quote":"After opposing counsel flagged the problem, Sabatini filed an untimely reply acknowledging the citations were “erroneous or unverifiable” and sought to withdraw eight cases.","source_index":0,"when":null}]},"model":"claude-haiku-5-5","prompt_version":"backfill-2026-11-01.2","extracted_at":"2026-11-01","source_urls":["https://floridapolitics.com/archives/806892-no-substitute-for-actual-intelligence-federal-appeals-court-refers-anthony-sabatini-for-discipline-over-ai-faked-citations/"]}}