Background
Sean Ryan appealed a final judgment of paternity entered by the Miami-Dade Circuit Court. His appeal challenged the child-support and income calculations and certain evidentiary rulings from the final hearing.
Ryan, who represented himself and is a member of the Florida Bar, filed an initial brief that extensively relied on hallucinated citations. Perez’s answer brief identified at least ten cited cases as nonexistent, miscited, or unsupported for the propositions Ryan advanced.
The Court’s Holding
The Third District affirmed the final judgment. It held that Ryan’s arguments lacked merit and that competent, substantial evidence supported the trial court’s determinations.
The court also denied Ryan’s post-answer-brief motion for leave to file a corrected initial brief. The motion did not attach the proposed replacement brief or provide a sufficient reason for allowing Ryan to rebrief the appeal. Although the court declined to issue an order to show cause under the case’s unique circumstances, it warned that future failures to verify cited authorities would result in sanctions.
Key Takeaways
- Competent, substantial evidence supported the paternity judgment’s child-support and income determinations.
- An appellant is not entitled to rebrief an appeal merely to correct hallucinated citations identified in the answer brief.
- Lawyers, including self-represented lawyers, must verify legal citations before filing; future violations may lead to sanctions.
Why It Matters
The decision reinforces that fabricated or unsupported authorities undermine appellate advocacy and can expose counsel to sanctions. The court treated the citation failures as especially serious because they went to the core of Ryan’s arguments and he was a Florida Bar member.