A federal appeals court called out a Florida county commissioner and recent congressional candidate for apparent AI-generated errors in his legal briefs, as part of its ruling in a religious bias case filed against Atlas Air Inc.
Anthony F. Sabatini, an attorney and commissioner for Lake County, Fla., submitted “multiple briefs replete with fake and hallucinated citations” in representing a group of aviation employees claiming the airline’s Covid-19 policies violated federal civil rights law and other statutes, Judge Britt C. Grant wrote in a Friday decision for the US Court of Appeals for the Eleventh Circuit.
Sabatini’s opening brief included at least eight case citations hallucinated by artificial intelligence, and when Atlas Air pointed out the error, he withdrew eight cases that were not among the original ones identified but were also fake, Grant wrote for the unanimous three-judge panel. Until last month, Sabatini was running as a Republican for the US House seat in Florida’s 11th district, and he previously served in the Florida House of Representatives.
“By outsourcing his legal work to an AI algorithm, Sabatini violated his ethical duties to both his clients and this Court,” the judge wrote.
Federal courts are increasingly seeing AI hallucinations in legal filings, often leading to sanctions or even temporary bans from appearing for the lawyers at fault. Grant wrote the typical response to an AI-based error would be an apology from the attorney with sanctions to follow, but it is “rare to see the kind of blatant and repeated misconduct that Sabatini has committed in this case.”
Judges rely on and review lawyers’ briefs carefully to reach their decisions, Britt wrote.
“All that is lost if a lawyer decides that it is not worthwhile to do the work to persuade us — if he is willing to sign his name on whatever a machine churns out without so much as checking it for accuracy,” the judge wrote.
The court will refer the matter to its Committee on Lawyer Qualifications and Conduct, according to the decision.
As for the claims against Atlas Air, Britt wrote they were “remarkably weak” and reaffirmed the Florida district court’s decision to dismiss them.
The employees, who were contractors hired by Flight Services International and working for Atlas Air, failed to prove the airline showed any animosity toward their religious beliefs, and did not show a hostile work environment under Title VII of the 1964 Civil Rights Act, Friday’s ruling said. Their objections centering on Atlas Air’s masking and testing policies were largely political and logistical, instead of religious, according to the decision.
The Eleventh Circuit also rejected the employees’ constitutional, food and drug safety, and state tort claims, including privacy violations.
Judges Robin S. Rosenbaum and Embry J. Kidd heard the case alongside Grant.
Sabatini and attorneys for both parties did not immediately return a request for comment.
Sabatini Law Firm and John Pierce Law represented the aviation employees. Jones Day represented Atlas Air, and Cole Scott & Kissane represented Flight Services International.
The case is Estate of Lane Caviness v. Atlas Air, Inc., No. 24-11033, 7/10/26