Court Considering Whether Litigant Should Be Barred from Further Self-Represented Filings, Because of Fabricated Citations
We affirm the appeal in all respects and issue a separate order to show cause as to why Gouldy should not be barred from further pro se filings in this court. Gouldy's excessively long pro se brief contains frivolous arguments, misrepresentations of the record, a phantom case, and fake quotes from actual cases…. This case demonstrates a growing problem in Florida's appellate courts.
- ▪We affirm the appeal in all respects and issue a separate order to show cause as to why Gouldy should not be barred from further pro se filings in this court.
- ▪Gouldy's excessively long pro se brief contains frivolous arguments, misrepresentations of the record, a phantom case, and fake quotes from actual cases….
- ▪This case demonstrates a growing problem in Florida's appellate courts.
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Record
| Original publisher | Reason Magazine |
| Canonical URL | https://reason.com/volokh/2026/07/24/court-considering-whether-litigant-should-be-barred-from-further-self-represented-filings-because-of-fabricated-citations/ |
| Publication time | Fri, 24 Jul 2026 13:03:11 +0000 |
| Retrieval time | 2026-07-24T13:17:46.118Z |
| Last seen | 2026-07-24T13:17:46.118Z |
| Headline source | Publisher (no WeSearch rewrite) |
| Excerpt source | publisher body |
| Excerpt method | First ~120 words (~800 chars) of extracted publisher body, fair-use limited. |
| Summary | WeSearch · cerebras-chat (WeSearch summarizer) |
| Summary source text | contentText |
| Citation coverage | Summary is a WeSearch-generated derivative; primary citation is the original publisher URL. |
| Cluster | WGgFODD4ezNN |
| Cluster logic | Grouped by semantic title/content similarity across sources within a rolling window. Same-publisher template collisions are excluded from coverage comparison. |
| Ranking reason | Story pages are not engagement-ranked. Hub feeds use recency, with optional source-diversified chronological ordering (cap consecutive stories per source). No personalized ranking. |
| Publisher visit | Yes — open original |
| Substitutes article? | No — link-out required for full text |
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| Indexing | May the item be indexed (stored, ranked, made findable)? | Allowed |
| Snippet | May a short excerpt of the publisher's text be shown? | Allowed |
| AI summary | May WeSearch generate its own short summary of the article? | Limited |
| Retrieval / RAG | May the content be exposed for third-party retrieval-augmented generation? | Not asserted |
| Model training | May the content be used to train AI models? | Not asserted |
| Commercial reuse | May the content be reused commercially? | Not permitted |
Basis: Derived from the published RSS/Atom feed. Contact: [email protected]. Reviewed: 2026-07-24.
Opening excerpt (first ~120 words) tap to expand
AI in Court Court Considering Whether Litigant Should Be Barred from Further Self-Represented Filings, Because of Fabricated Citations The court orders the litigant to explain why she shouldn't be so barred, and notes that hallucinated citations are "a growing problem in Florida's appellate courts." Eugene Volokh | 7.24.2026 9:03 AM From Gouldy v. Chiasson, decided Wednesday by the Florida Court of Appeal (Judge Robert Gross, joined by Judges Melanie May and Spencer Levine): This appeal arises from a frivolous underlying lawsuit Gouldy brought against Chiasson, an attorney, in connection with Chiasson's actions in representing appellees Amanda Munyan and Michael Peak in a related probate matter involving Gouldy.
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Excerpt limited to ~120 words for fair-use compliance. The full article is at Reason Magazine.