Lake County Commissioner and attorney Anthony Sabatini filed court briefings that were “riddled with nonexistent ‘hallucinated’ cases,” according to an opinion from a federal appeals court that scolded Sabatini for “substandard” work that was generated using artificial intelligence, or AI.
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A panel of the 11th Circuit Court of Appeals used an opinion upholding a lower court ruling — one in which Sabatini represented the losing side — to criticize the Lake attorney’s legal work. It said it would refer the matter to a committee that oversees attorney discipline and professional conduct.
Judge Britt Grant, an appointee of President Donald Trump who wrote the opinion, said the claims in the case, which involved a suit against an airline’s COVID-19 masking and testing policies, were “remarkably weak” and that, by outsourcing his legal work to AI, Sabatini had “violated his ethical duties” to his clients and to the court.
“We are more candid than usual in this assessment because the plaintiffs’ counsel Anthony F. Sabatini has not been candid with us,” Grant wrote. “Sabatini filed multiple briefs replete with fake and hallucinated citations. Even after being warned.”
Sabatini didn’t immediately respond to a request for comment on Friday afternoon.
The ruling was first reported by Florida Politics. The publication noted its story “was drafted with assistance from AI.”
The court said it would refer the matter to the Committee on Lawyer Qualifications and Conduct, which investigates grievances against lawyers and provides disciplinary recommendations to the chief judge, according to the court’s website.
“Whatever the merits of artificial intelligence, it is no substitute for actual intelligence,” Grant wrote in the opinion backed by the other judges on the panel.
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“By signing his name on briefs filled with hallucinated citations—not once but twice—Sabatini violated his professional obligations, both to his clients and to this Court,” she said. “If he thinks these claims are not worth the effort, he should either tell his clients they fall short or advise them to hire another lawyer — not file obviously insufficient pleadings and briefs generated by AI tools.”
Sabatini is a former state representative who has recently taken on a number of cases that aim to get Central Florida candidates tossed from ballots by claiming they didn’t meet filing requirements or aren’t eligible to run.
Last month, Sabatini filed a suit on behalf of one of U.S. Rep. Cory Mills’ GOP opponents seeking to oust the embattled Central Florida congressman from the primary ballot, arguing that he didn’t sign a key election document and that a judge should declare his candidacy invalid.
Sabatini also is suing County Commissioner Maribel Gomez Cordero, who is running for Orange County Clerk of Courts on behalf of one of her opponents, former Property Appraiser Rick Singh.
The 37-year-old has made headlines for years for his controversial and often insulting social media posts and was warned by Republican leaders in Tallahassee to tone down his remarks even before he even attended his first legislative session in 2019.
In the past, he has tweeted a picture of an AR-15 targeted at George Floyd protesters, called for ending gay marriage and, when he ran unsuccessfully for the U.S. House of Representatives four years ago, posted on X, “I’m running for Congress to imprison as many Democrats as possible.”
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Lake County voters elected him to the County Commission in 2024.