Lisandrillo v. Palozzi

What happened

Lisandrillo v. Palozzi arose from a Broward County dissolution of marriage case in which the trial court had appointed a guardian ad litem (a neutral appointed to investigate and report on a child's best interests). After the trial court held the petitioner in contempt on July 14, her counsel filed a 33-page motion to disqualify the judge, which was denied as legally insufficient. On July 31 counsel filed a 61-page emergency petition for a writ of prohibition that also sought certiorari review of seven other rulings.

The Fourth District read that petition alongside counsel's earlier filings: a 41-page "Urgent Omnibus Application" requesting 13 forms of relief, an 11-page emergency motion requesting nine, and three motions in limine. The court opened by describing "what appears to be 'AI slop.'" A footnote made clear that the problem was not hallucinated law. The citations were real and the cases existed. The court instead listed red flags it treated as indicia of non-human authorship: an emergency request with no emergency, eight rulings challenged in one proceeding, reliance on an unpublished order in an unrelated case, and a disqualification motion arguing 14 grounds.

Two features of the Lisandrillo filings bear on AI directly. The disqualification motion began with the argument that filing such a motion automatically stays the trial court, which the panel called an argument "often seen in AI hallucinations." The motion also relied on an unofficial rough draft transcript to allege that the judge repeatedly misnamed counsel. The official transcript showed no such errors, and the court wrote that it suspected "AI generated these bogus arguments from mistranscriptions."

What the court did

Writing for the panel, Judge Gross denied the prohibition petition and the certiorari requests in the opinion. The court found many allegations contrary to the record and called the scattershot structure "issue churning," describing AI-assisted documents that raise long lists of convoluted arguments. It declined to decide how the filings were produced: "whether this was AI-generated, AI-assisted, or something else makes no difference. An attorney is obligated to stand behind any submission to a court."

The opinion listed Florida Bar rules the conduct implicates: competence, the adviser's duty of independent professional judgment, meritorious claims and contentions, expediting litigation, candor toward the tribunal, and the rule on fees. It then directed counsel, Jaclyn R. Soroka, to respond within 10 days and show cause "without the use of AI" why sanctions, such as referral to the Florida Bar for consideration of disciplinary proceedings, should not be imposed under Florida Rule of Appellate Procedure 9.410(a).

Where it stands

The Lisandrillo opinion, No. 4D2026-2262, is dated September 16 and carries the standard notice that it is not final until any timely rehearing motion is resolved. Counsel's response to the show-cause order, and any sanction or Bar referral that followed, were not located as of October 30. The trial court had not yet fixed the makeup timesharing or the amount of fees awarded as a contempt sanction, and the opinion notes that those rulings will be appealable once entered.

The panel placed Lisandrillo alongside its earlier sanctions against self-represented litigants for abusive AI filings in Avery v. Beauzil and Gouldy v. Chiasson, stating that courts "must require more from attorneys."

The obligation it engaged

Lisandrillo engages Clause 2 of the Standard, non-delegation, more than any citation clause. The court's concern was that arguments appeared to have been assembled by a system rather than formed through counsel's own judgment, and it tied that concern to the Bar rule requiring independent professional judgment. Clause 3, independent authority, applies to the factual assertions: statements about what the judge said were drawn from an unofficial rough transcript and not checked against the official record.

Clause 1, sequence, frames the lesson for an expert witness. An expert who forms and records a view before consulting a system produces a report with a limited number of reasoned opinions. One who lets a system generate the opinions risks the volume and incoherence the Fourth District described. Real citations do not cure analysis the professional did not perform. The direction to respond without AI also shows that a tribunal may restrict a professional's tools once their use is in question.

Sources

• District Court of Appeal of Florida, Fourth District (copy hosted by the AI Hallucination Cases database, Damien Charlotin) · September 16, 2026
  Lisandrillo v. Palozzi, No. 4D2026-2262, opinion

What could not be confirmed

The court did not find that AI was used; it stated a suspicion and said the source made no difference. The opinion gives the judges' surnames only. Any rehearing motion, counsel's show-cause response, and any sanction or Florida Bar referral were not located as of October 30, 2026. The copy on the Fourth District's own website was not opened for this entry.