You can't file what you can't verify. Here's how to check every citation in a Florida pleading.
In 2023, a New York attorney filed a brief full of case citations that ChatGPT invented. The cases didn't exist. The judge in Mata v. Avianca sanctioned the attorney $5,000, and the story made national news. That was the moment courts started paying attention to AI-generated legal work.
Since then, federal and state courts have started requiring attorneys to certify that AI was not used, or that AI-generated content was independently verified. Florida judges are watching. If you file a document with a fabricated citation, "I used ChatGPT" is not a defense. It's an aggravating factor.
Attorneys with Westlaw or Lexis subscriptions can cross-check citations. It takes time, but the tools exist. Pro se litigants don't have that option. A Westlaw subscription costs hundreds of dollars per month. So what do you do?
You verify. Every single citation. Before it goes to the court.
Bottom line: Courts don't care how the bad citation got into your filing. They care that it's there. Whether you drafted it yourself, hired a lawyer, or used AI, the responsibility is yours.
Every Florida court filing uses some combination of three citation types. Each one has its own format, its own verification challenges, and its own failure modes.
Case law is cited using reporter abbreviations. In Florida, you'll see Southern Reporter citations like Smith v. Jones, 123 So. 3d 456 (Fla. 2020). You might also see Florida Law Weekly citations for recent opinions that haven't made it into the bound reporters yet. Federal cases use F.3d, F.4th, F. Supp., and similar reporters. The format is always: party names, volume number, reporter abbreviation, page number, court, and year.
Statutes follow the pattern Fla. Stat. § 83.49 or the shorthand § 83.49, F.S. Florida organizes its statutes by title, chapter, part, and section. Chapter 83 is landlord-tenant law. Part I covers commercial tenancies. Part II covers residential. Getting the chapter right but the part wrong is one of the most common mistakes.
Rules of Civil Procedure are cited as Fla. R. Civ. P. 1.510. There are 78 rules total. They govern how cases move through court: filing deadlines, discovery, motions, trial procedures. Rules get amended and renumbered, so older references sometimes point to outdated numbering.
Case citations are the hardest to verify because there are millions of cases, and a fabricated citation can look completely legitimate. Here's where to check them.
CourtListener (free) is an open database run by Free Law Project. It has millions of court opinions and is searchable by party name, citation, and docket number. If a case exists, CourtListener probably has it. Go to courtlistener.com, search for the case name or citation, and see if it returns a match.
Google Scholar (free, limited) has a legal opinions section. Click "Case law" on Google Scholar, search for the case name, and it will show you opinions from state and federal courts. The limitation: Google Scholar doesn't have everything, and it doesn't always show the exact reporter citation you need to confirm.
Westlaw and Lexis (expensive) are the gold standard. If you have a subscription, KeyCite or Shepardize every case. These tools tell you not just if the case exists, but if it's still good law. For most pro se litigants, this isn't an option.
What to check for every case citation: Does the case actually exist? Is the volume/reporter/page number correct? Does the holding say what you claim it says? Has the case been overruled or distinguished? A case can be real and still be wrong for your argument.
The Florida Senate maintains the official statutes at flsenate.gov. You can browse by title and chapter, or search for a specific section number. It's free, it's authoritative, and it's always current.
The problem is speed. Florida has 637 active chapters and over 24,800 individual sections. If your filing cites 10 statutes, you're navigating to 10 different chapter pages, scrolling through tables of contents, and confirming each section exists and says what you think it says.
Here's the chapter/part/section structure you need to understand. Take Chapter 83 (Landlord and Tenant). It has two parts:
Part I: Nonresidential Tenancies, covering sections 83.001 through 83.251.
Part II: Residential Tenancies, covering sections 83.40 through 83.683.
Citing § 83.49 (residential security deposits) in a commercial lease dispute is wrong, even though "Chapter 83" is correct. You need section-level verification, not just chapter-level.
Also watch for repealed sections. Florida periodically reorganizes its statutes. A section that existed in 2019 may have been repealed, transferred, or renumbered. If you're working from older templates or AI-generated drafts trained on old data, you could be citing law that no longer exists.
The Florida Bar's website publishes the current Rules of Civil Procedure. There are only 78 of them, so this is the easiest category to verify manually. But "easy" doesn't mean "foolproof."
The main risk is outdated rule numbers. When the Florida Supreme Court amends the rules, numbering can shift. Rule 1.510 (Summary Judgment) was substantially amended in 2021 to align with the federal standard. If you're citing pre-amendment language, your argument may not match what the rule currently says.
Also watch for rules that people commonly confuse. Rule 1.500 governs defaults. Rule 1.510 governs summary judgment. Rule 1.525 governs motions for attorney's fees. One digit off and you're citing the wrong procedural mechanism entirely.
Quick check: If a rule citation doesn't appear in the Florida Bar's current list, it either doesn't exist or has been renumbered. Don't assume it's valid just because it follows the right format.
You can do all of this manually. Check CourtListener for cases, flsenate.gov for statutes, the Florida Bar for rules. For a document with 15-20 citations, budget an hour or two.
Or you can upload your document to AI Detector Pro and have every citation checked in a couple of minutes.
ADP extracts every citation from your filing, whether it's a PDF, Word document, or plain text. Case citations are searched against CourtListener, Google Scholar, and multiple web sources. Statutes are checked section-by-section against the complete 2025 Florida Statutes index. Rules are verified against the current list of 78 valid rules.
You get a Verification Report showing which citations exist, which don't, and which might be problematic. If you want to go deeper, the Deep Analysis runs multiple independent AI models to assess whether each citation actually supports the argument it's being used for.
It's not a replacement for legal judgment. It's a way to catch the errors before the court does.
