Florida Court Threatens Sanctions Over AI-Generated Legal Filings
Florida appeals court threatens sanctions against counsel for AI-generated filings in Lisandrillo v. Palozzi.
Why it matters: Attorneys must ensure thorough personal review of AI-generated documents to avoid court sanctions and ethical breaches. This ruling signals stricter scrutiny on AI-assisted filings in daily practice.
- On Sept. 16, 2026, Florida Fourth District Court of Appeal ruled that filings in Lisandrillo v. Palozzi showed incoherent, AI-generated content despite accurate citations.
- Judge Robert Gross labeled the 61-page emergency petition and 33-page motion as 'frivolous' and ordered counsel Jaclyn R. Soroka to respond without AI use within 10 days or face sanctions.
- The Florida Supreme Court amended rules in May 2026 requiring certification of accuracy for cited legal authority, aiming to curb AI-related filing errors.
- Legal experts emphasize that attorney oversight is essential as AI drafts become more common, or risk compromising legal standards.
On September 16, 2026, the Florida Fourth District Court of Appeal issued a decision criticizing filings in Lisandrillo v. Palozzi for containing incoherent arguments typical of AI-generated text. The court scrutinized a 61-page emergency petition and a 33-page motion to disqualify a trial judge submitted by attorney Jaclyn R. Soroka.
Judge Robert Gross found that despite including real legal citations, the documents showcased "gibberish," with disorganized reasoning and frivolous claims suggestive of AI drafting without adequate attorney input. He characterized the filings as an abuse of the litigation process and ordered Soroka to explain within 10 days why sanctions, including referral to the Florida Bar for potential disciplinary action, should not be imposed. A key condition was that her response must be prepared without AI assistance.
This case illustrates increasing judicial concern over the reliability and ethical implications of AI tools in legal writing. Legal ethics experts Jodi Swick and Jarrett Ganer explained that AI-generated content requires meaningful attorney oversight because the technology can produce plausible but flawed reasoning that undermines legal advocacy.
In response to similar risks, the Florida Supreme Court amended statewide court rules in May 2026 to require all attorneys and self-represented litigants to certify that cited legal authorities in filings are accurate and complete. This step aims to mitigate inaccuracies that AI might propagate, as noted by The Florida Bar.
The Lisandrillo ruling underscores that while AI tools can aid legal drafting, attorneys remain ethically and professionally responsible for the content they submit. Courts are increasingly ready to impose sanctions if AI-generated filings are not properly reviewed—highlighting the importance of vigilance in everyday legal practice.
By the numbers:
- 61 pages — length of AI-criticized emergency petition in Lisandrillo case
- 33 pages — length of the accompanying motion to disqualify the judge
- 10 days — deadline for counsel to respond without AI before possible sanctions
Yes, but: While the ruling is firm, the court allows counsel to avoid sanctions by demonstrating proper human review and preparation without AI, reflecting a balanced approach to emerging technology.
What's next: Legal professionals should monitor ongoing rule revisions and pending cases that may further define AI's permissible role in filings.