Court Filings, Hallucinations & Sanctions · November 2026
Lisandrillo v. Palozzi
___ So. 3d ___, No. 4D2026-2262 (Fla. 4th DCA Sept. 16, 2026)
Florida appellate court denies a writ petition and issues a show-cause order over counsel's “AI slop” and AI-driven “issue churning,” which “ha[d] nothing to do with hallucinated law or false legal citations.”
In a dissolution case, counsel filed a 61-page emergency petition, a 33-page disqualification motion, and other lengthy filings the court described as “AI slop” containing “gibberish” and “convoluted, false, and frivolous arguments.”
The court emphasized that the problem had “nothing to do with hallucinated law” — the cited cases were real — but that the reasoning showed the arguments “were assembled by an AI tool rather than developed through a trained advocate's independent judgment.” It identified “issue churning,” in which AI-assisted documents “aggressively raise scattershot arguments,” and suspected AI had generated “bogus arguments” from errors in a rough-draft transcript.
Whether the filings were AI-generated “makes no difference,” the court held, because “[a]n attorney is obligated to stand behind any submission to a court.” The court also flagged billing concerns, noting that “[i]t takes almost no skill and little time to generate AI slop,” and ordered counsel to show cause — “without the use of AI” — why sanctions, including a Florida Bar referral, should not be imposed.