On July 11, 2026, the U.S. Court of Appeals for the Eleventh Circuit, with Judges Britt Grant, Robin Rosenbaum, and Embry Kidd presiding, affirmed the dismissal of a lawsuit challenging pandemic-era workplace Covid-19 policies. The case involved a group of commercial aviation employees who opposed their employers’ mask, testing, and vaccination mandates during the Covid-19 pandemic.

The district court had dismissed the plaintiffs' third amended complaint for lack of personal jurisdiction and failure to state a claim, a decision the appellate court upheld. The plaintiffs alleged that their employers’ Covid-19 protocols created a hostile work environment under Title VII, violated the Federal Food, Drug, and Cosmetic Act, infringed on federal constitutional rights, and caused tortious invasion of privacy, negligent disclosure of private medical information, and emotional distress.

The lawsuit was notably marked by serious procedural issues attributed to the plaintiffs' counsel, Anthony F. Sabatini, an elected County Commissioner for Lake County, Florida, and former state representative. Sabatini, 37, who has a history of controversial and often insulting social media posts and was previously warned by Republican leaders in Tallahassee to moderate his remarks before his first legislative session in 2019, filed multiple legal briefs containing fabricated and hallucinated citations.

The court’s opinion candidly criticized Sabatini’s conduct, stating that it is "rare to see the kind of blatant and repeated misconduct that Sabatini has committed in this case." His opening brief relied on at least eight fictitious cases, including one purportedly decided by the Eleventh Circuit itself. After the defendants pointed out 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.

The court underscored the importance of competent legal representation, noting that attorneys "shall provide competent representation to a client" and emphasizing that the "use of AI requires caution and humility." This suggests that Sabatini’s reliance on artificial intelligence tools without adequate verification contributed to the inclusion of false citations.

During the Covid-19 pandemic, the companies involved required employees to vaccinate against Covid-19 unless they obtained religious or medical exemptions, in which case they were subject to periodic testing and mask-wearing on the job. The plaintiffs personally rejected these policies, which formed the basis of their claims.

Additionally, the court found that exercising personal jurisdiction over one defendant, Flight Services International, would violate due process because neither general nor specific jurisdiction was available in Florida for that company.

This ruling highlights the judiciary’s scrutiny of legal filings and the emerging challenges posed by AI-generated content in legal practice, especially when it leads to fabricated or unverifiable citations.

Sources

Key Entities

  • Anthony F. Sabatini, Lake County, Florida County Commissioner
  • Eleventh Circuit Court of Appeals
  • Judges Britt Grant, Robin Rosenbaum, Embry Kidd
  • Flight Services International
  • Plaintiffs: Commercial aviation employees

What to Watch

The case underscores the need for legal professionals to verify AI-generated content rigorously. It also reflects ongoing tensions around Covid-19 workplace policies and the legal boundaries of jurisdiction in multi-state corporate litigation.