Case D-167 · AI Sanctions Case Tracker

Lisandrillo v. Palozzi

No. 4D2026-2262, Florida Fourth District Court of Appeal, show-cause order September 16, 2026; RESOLVED October 21, 2026, referred to the Florida Bar for possible discipline (attorney Jaclyn Soroka)

Response class R5, Denied or Doubled Down

“Abusive AI filing threatens the orderly administration of justice. Courts must require more from attorneys and not tolerate abusive practice fueled by AI.”

Judge Gross, for the panel, in Lisandrillo v. Palozzi

The case

Florida Fourth District Court of Appeal (West Palm Beach), show-cause order issued Wednesday, September 16, 2026, reported September 17, 2026, in Lisandrillo v. Palozzi, No. 4D2026-2262, a dissolution-of-marriage appeal. Three-judge panel: Judge Robert Gross, joined by Judges Levine and Shepherd (the panel members' first names, Spencer Levine and Caroline Shepherd, are from reporting; the held opinion gives surnames only). Attorney: family-law attorney Jaclyn Soroka, representing the wife, who had challenged lower-court rulings including the denial of her bid to disqualify a lower-court judge. The September 16, 2026 opinion is cited at 2026 WL 2727559 (Fla. 4th DCA Sept. 16, 2026) (the cite given in the October 21, 2026 resolution order). Held primary documents (files/sources/): the September 16 show-cause opinion (`D-167-lisandrillo-v-palozzi-opinion.pdf`), Soroka's response to the OSC (`D-167-soroka-osc-response.pdf`), and, as of November 1, 2026, the October 21, 2026 resolution order itself (`D-167-lisandrillo-resolution-order-2026-10-21.pdf`, 2 pp., per curiam; fetched from the court PDF hosted on CourtListener storage during EP20's Gate 0 verification, which confirmed its language line by line against the reporting below). Reporting: https://www.reuters.com/legal/litigation/appeals-court-warns-about-ai-slop-filings-weighs-punishing-lawyer-2026-09-17/

What happened

The panel said Soroka's filings bore hallmarks of generative-AI output that it called "AI slop", lengthy, unfocused submissions containing "frivolous, scattershot arguments" and prose the court described as "gibberish" ("An AI supercomputer would struggle to find meaning in some of the prose used in this case."). Notably, the court did NOT say the filings contained hallucinations or fabricated material; it expressly distinguished this matter from hallucination cases. The panel said the filings "resemble what we typically see from vexatious pro se litigants" and "appear designed to cause delay." Soroka declined to say whether or how she used AI in preparing the filings; she told Reuters she takes the ruling seriously and will respond to it in court.

The rule and the sanction

RESOLVED October 21, 2026: in a brief order, the panel rejected Soroka's show-cause response and referred her to the Florida Bar for possible professional discipline. No monetary sanction was reported. The panel said Soroka "does not deny using AI but evades the issue and attempts to defend the frivolous arguments discussed in our prior opinion," and that "a lawyer taking responsibility for a pleading she signed does not relieve the lawyer of responsibility for the pleading's contents." The original September 16, 2026 order had directed Soroka to respond within 10 days (by ~September 26, 2026) as to why she should not be sanctioned, and the court said it would consider referring her to the Florida Bar for disciplinary proceedings. The panel framed the misconduct as a failure of independent professional judgment and comprehensibility: "Counsel's arguments need to be comprehensible to human readers — the courts, opposing counsel, and the litigants." Judge Gross wrote: "Abusive AI filing threatens the orderly administration of justice. Courts must require more from attorneys and not tolerate abusive practice fueled by AI." The court said it ultimately does not matter whether "this was AI-generated, AI-assisted, or something else", attorneys must stand behind any filing they submit. Source (resolution): https://www.reuters.com/legal/litigation/florida-lawyer-referred-possible-discipline-over-filing-that-judges-called-ai-2026-10-21/

Status update (October 1, 2026): on Monday, September 28, 2026, Soroka filed her response to the show-cause order, reported September 30. Page count: the e-filed PDF runs 84 pages including the filing header and cover; the October 21, 2026 resolution order characterizes it as "an 82-page response." Either figure is supportable with its basis named; do not state a page count without one. She told the court she "does not delegate her work or reasoning to AI" and that "No filing I made to this court was frivolous"; she said the court identified no fabricated authorities ("My citations are real, my cases exist, and my language is confident because the record supports it"). She cited Florida Bar Advisory Opinion 24-1 (lawyers may use AI but remain responsible for their work product) and told Reuters she uses AI "the way I use any modern technology to run my practice" but has not used AI programs to generate a court filing. No ruling from the court has been reported as of October 1, 2026. Source: https://www.reuters.com/legal/litigation/florida-lawyer-denies-submitting-ai-slop-bid-dodge-court-sanctions-2026-09-30/

Resolution (October 21, 2026): the Fourth District Court of Appeal rejected Soroka's response and referred her to the Florida Bar for possible professional discipline, reported October 21, 2026 by Reuters. The panel said she "does not deny using AI but evades the issue and attempts to defend the frivolous arguments discussed in our prior opinion." Soroka acknowledged that a filing in the lower-court proceeding contained a false quotation to a prior case, which she attributed to human error and time pressures; she did not immediately respond to a request for comment on the referral and has denied submitting frivolous material. The referral is not itself a suspension or a final Bar penalty; any further discipline depends on the Florida Bar process. Both orders carry the standard "not final until disposition of timely-filed motion for rehearing" language. Source: https://www.reuters.com/legal/litigation/florida-lawyer-referred-possible-discipline-over-filing-that-judges-called-ai-2026-10-21/ ; corroboration: https://www.jdjournal.com/2026/10/22/florida-lawyer-ai-court-filing-discipline/

How the lawyer responded

R5, Denied or Doubled Down (re-graded November 1, 2026, at EP20's Gate 0 against the held documents, resolving the R0 placeholder carried while the OSC was outstanding). Basis: Soroka denied delegating her work or reasoning to AI and denied frivolousness outright ("No filing I made to this court was frivolous"); defended the frivolous arguments rather than withdrawing them (the panel's finding); answered the AI question by evasion (the panel's finding, the R4 element in the record); and the one error she admitted, the false quotation, was subordinate, recharacterized as human error under time pressure, and drawn from a filing in the lower-court proceeding, not the appellate filings. No remediation is recorded. The panel rejected the response in full and referred the matter to the Florida Bar; the dominant note is the doubling down, she maintained the practice itself was acceptable.

How it could have been avoided

The duty extends beyond citation accuracy to independent professional judgment and comprehensibility. Read and reshape every AI-assisted draft into a coherent, focused argument before filing, "AI slop" (scattershot, unfocused, near-gibberish prose) can draw sanctions scrutiny even with zero fake citations. Verify not just what the filing says but whether it says anything intelligible: courts assess whether the prose resembles that of a vexatious litigant and whether the arguments reflect the lawyer's own professional judgment, not merely whether the citations check out.

Sources