Court Orders Plaintiff to File Handwritten Opposition,

after noting that many of plaintiff's filings contained seeming AI hallucinations, despite assertions in plaintiff's filings that all the citations were valid.

From Judge Aileen Cannon (S.D. Fla.) in Paulk v. Larva Labs, LLC, decided in June but just posted on Westlaw:

This case presents a dispute over Defendant's alleged fraudulent interference with Plaintiff's Non-Fungible Tokens ("NFTs"). Plaintiff's Complaint, initially filed in Florida state court on January 20, 2026, alleges that in June 2017, Plaintiff used a publicly available software tool to generate 141 NFTs on the Ethereum blockchain. Each of these NFTs represents ownership of a unique CryptoPunk that was part of the first version of CryptoPunks ("V1"), a pioneering generative art project consisting of 24x24 pixel portraits. To create the NFTs, Plaintiff paid only nominal "gas fees" (i.e., fees paid to third parties who validate transactions on the Ethereum blockchain), and the NFTs "have remained in [a] dormant wallet" controlled to this day by Plaintiff.

Plaintiff alleges that, on June 23, 2017, Defendant "deployed" a second version of CryptoPunks ("V2"), "claiming V1 contained a 'bug.'" The Complaint then asserts that Defendant "suppressed V1 marketplace activity while promoting V2 as the sole authoritative collection, rendering Plaintiff's assets commercially impaired". Based on these allegations, the Complaint asserts causes of action for fraudulent concealment (Count I), unjust enrichment (Count II), declaratory relief (Count III), and injunctive relief (Count IV), seeking unspecified monetary damages and an injunction.

The court discussed various procedural issues, and then added:

As a separate matter, the Court is concerned more generally about the plethora of legal filings seemingly prepared by artificial intelligence and submitted by Plaintiff that make frivolous and unsupported arguments to the Court [see, e.g., ECF Nos. 15, 16, 17, 18, 19, 26, 26-1, 31, 32, 33]. As an example, Plaintiff makes the obviously incorrect submission that the citizenship of Defendant's counsel can be considered in determining complete diversity.

And many of Plaintiff's filings contain disclaimers to the Court, expressly certifying "that every legal authority, statutory provision, rule of procedure, and historical case citation referenced within [the filings] has been independently read, analyzed, verified, and cross-referenced against official federal and state legal repositories." In each of these filings, "Plaintiff guarantees that every cited case stands as valid, binding law within the United States Supreme Court and the Eleventh Circuit Court of Appeals, possesses an active and unchecked standing, and accurately represents the procedural postures asserted." And he expressly warrants that he has not included any "fictitious or unverified citations," and that he has "manually double-checked" each case to ensure that it "support[s] Plaintiff's cause perfectly, ensuring that no unverified or 'hallucinated' data is presented to the Court."

No doubt Plaintiff's artificial intelligence legal counsel told him to say all this. And the AI certainly had the right idea—litigants should not make misrepresentations to the Court. Unfortunately, Plaintiff did not practice what his artificial counsel preached. Instead, he cites to "Snapper v. Redan, 523 U.S. 83 (1998)"—a case which does not exist—for the proposition that "when a company's chief legal representative has been sent formal notification at a publicly advertised professional office location, the entity cannot assert an administrative breakdown within its secondary commercial mail hubs as an equitable basis to vacate an otherwise valid default". Notwithstanding the made-up citation, the case Plaintiff means to cite, Snapper, Inc. v. Redan (11th Cir. 1999), is an Eleventh Circuit case that says nothing of the sort. Instead, Snapper established that federal appellate courts have jurisdiction to review remand orders based on the enforcement of contractual forum selection clauses. It does not mention vacatur, or default, or even mail—and it certainly does not stand for the extremely narrow proposition for which Plaintiff cites it.

In light of all this, Plaintiff has violated his duty of candor to the Court and has committed a Rule 11 violation…. [T]he Court [therefore] imposes filing sanctions as follows:

1. Until Defendant's forthcoming Motion to Dismiss is resolved, Plaintiff shall not file any motion or submit any item on the docket unless Plaintiff first files a motion for leave to file the designated motion/filing and obtains the Court's approval to file the requested material. Except as stated in this Order, any motion or item on the docket that is filed by Plaintiff without this mandatory judicial pre-approval will be stricken without further notice.
2. Notwithstanding the above requirement, Plaintiff may file an opposition to Defendant's forthcoming Motion to Dismiss in accordance with the local rules of this district. See S.D. Fla. L. R. 7.1(c). Due to Plaintiff's prior artificial intelligence offenses, any such opposition shall be handwritten, and shall refrain from containing any inaccurate citations or hallucinated authority. The failure to comply with any aspect of this Order may cause the Court to grant the forthcoming Motion to Dismiss by default.

Plaintiff failed to respond to the motion to dismiss, and in a later opinion the court granted that motion.