On Saturday, July 11th, 2026, the Eleventh Circuit Court of Appeals, with Judges Britt Grant, Robin Rosenbaum, and Embry Kidd presiding, affirmed the dismissal of a lawsuit involving pandemic-era workplace policies in the commercial aviation sector. The case drew attention not only for its legal merits but also for the conduct of plaintiffs' counsel, Florida politician Anthony F. Sabatini, who was sharply criticized for filing briefs containing multiple fake and hallucinated legal citations.

The lawsuit stemmed from a group of commercial aviation employees who opposed their employers' COVID-19 protocols, including mask mandates, testing, and vaccination requirements. These companies mandated vaccination unless employees obtained religious or medical exemptions, in which case they were subject to periodic testing and mask-wearing on the job. The plaintiffs alleged that these protocols created a hostile work environment under Title VII and raised claims including violations of the Federal Food, Drug, and Cosmetic Act, federal constitutional rights, invasion of privacy, negligent disclosure of medical information, and infliction of emotional distress.

However, the district court dismissed the third amended complaint due to lack of personal jurisdiction and failure to state a claim, a decision the Eleventh Circuit upheld. The court noted that exercising personal jurisdiction over one defendant, Flight Services International, would violate due process as neither general nor specific jurisdiction was available in Florida for the company.

The case drew further scrutiny because of the conduct of Sabatini, who acted as plaintiffs' counsel. The Eleventh Circuit judges were unusually candid in their assessment, describing the claims as "remarkably weak, at least as pleaded." More notably, they condemned Sabatini for filing multiple briefs "replete with fake and hallucinated citations," including at least eight cases that were either erroneous, unverifiable, or entirely fabricated. Some of these citations purportedly referenced decisions by the Eleventh Circuit itself.

After the defendants identified these issues, Sabatini acknowledged in an untimely proposed reply brief that those citations were "erroneous or unverifiable" and sought to withdraw reliance on the eight listed cases. Despite this acknowledgment, the court's tone suggested the misconduct was severe and rare. The judges emphasized the professional obligation to provide competent representation and underscored that the use of AI in legal research and drafting requires "caution and humility."

Sabatini, 37, is an elected County Commissioner for Lake County, Florida, and a former state representative. He has previously attracted media attention for controversial and often insulting social media posts. Republican leaders in Tallahassee reportedly warned him to moderate his remarks even before his first legislative session in 2019.

This incident highlights the challenges and ethical considerations surrounding the integration of artificial intelligence tools in legal practice, especially when accuracy and reliability are paramount.

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