Clerk of the Court v. Rangel
The case
Clerk of the Court and Comptroller for the 13th Judicial Circuit v. Rangel, Fla. 2d DCA, No. 2D2024-1772, opinion filed August 29, 2025. Attorney: J. Tony Lopez (Tampa personal-injury and criminal-defense lawyer). Primary opinion: https://cases.justia.com/florida/second-district-court-of-appeal/2025-2d2024-1772.pdf?ts=1756480418 ; reported at: https://news.bloomberglaw.com/litigation/paralegals-ai-usage-lands-florida-lawyer-discipline-referral
What happened
A brief prepared with a paralegal's AI assistance misrepresented the holdings of opinions nine times, fabricated quotations from opinions ten times, and cited a case that does not exist.
The rule and the sanction
The court held "sanctions are appropriate" and referred Lopez to the Florida Bar for disciplinary proceedings.
How it could have been avoided
Supervising attorneys must verify AI-assisted work product from paralegals and staff: delegation to nonlawyers does not dilute the lawyer's Rule 5.3 supervisory duty. Misrepresenting what real cases hold is sanctionable even when the cases themselves exist; verify holdings, not just citations.