Kid International v. City National Bank — affirmed summary judgment and sanctioned appellants and counsel for fabricated citations

Case
Kid International, LLC, Lichi, LLC, and Yaron Katz v. City National Bank of Florida and 2655 SW 25, LLC
Court
Florida Fourth District Court of Appeal
Judge
Shaw, J. (Ron DeSantis, 2025); Gerber, C.J. (Charlie Crist, 2009); Lott, J. (Ron DeSantis, 2025)
Date Decided
October 7, 2026
Docket No.
4D2025-2599
Topics
Statute of limitations; Appellate sanctions; AI-generated citations; Attorney’s fees
Source
Read the full opinion

Background

Kid International, Lichi, and Yaron Katz appealed a Broward County circuit court’s final summary judgment for City National Bank of Florida and 2655 SW 25, LLC. The circuit court concluded that the plaintiffs’ claims were barred by the statute of limitations.

On appeal, the defendants sought sanctions, asserting that the plaintiffs’ initial brief relied on fabricated authorities, fictional quotations, and mischaracterizations of actual cases. The appellate court independently confirmed multiple errors, including citations to a nonexistent case and purported quotations that did not appear in cited opinions.

The Court’s Holding

The Fourth District affirmed the summary judgment without further discussion, holding that the record and applicable law supported the circuit court’s statute-of-limitations ruling.

The court also granted the defendants’ sanctions motion under Florida Rule of Appellate Procedure 9.410(b). Plaintiffs’ counsel acknowledged that the brief contained unverified and inaccurate authorities, explaining that the errors arose from client-provided research materials and the firm’s use of generative AI in its research and drafting process. The court held that fabricated and inaccurately cited authorities warranted an award of reasonable appellate attorney’s fees.

Key Takeaways

  • The judgment for defendants was affirmed because the claims were time-barred.
  • Hallucinated cases, fabricated quotations, and inaccurate descriptions of legal authorities are sanctionable in appellate filings.
  • The plaintiffs and their counsel are jointly and severally liable for defendants’ reasonable attorney’s fees incurred on appeal.

Why It Matters

The decision extends the Fourth District’s reasoning on sanctions for fabricated legal authority to a party-requested fee sanction under Rule 9.410(b). It underscores that counsel remains responsible for independently verifying every authority and quotation in a filing, including material generated with AI assistance or supplied by a client.

The circuit court must determine the amount of appellate fees on remand, including qualifying work on any rehearing motion.

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