Lisandrillo v. Palozzi: the October 21 order and what changed
A dated timeline from the court's own documents, the order's exact words for each figure, and how it differs from the September 16 opinion. Documents read on .
Status of the order
Referral to the Florida Bar, October 21, 2026. By its own terms the order is not final until a rehearing motion is disposed of.The order ends with its own finality line: “Not final until disposition of timely-filed motion for rehearing.” Treat the referral as subject to rehearing until the docket shows that motion, if any, disposed of.
What changed since September 16
| Document | What the court did |
|---|---|
| Opinion, Sept. 16 | Denied the petition; suspected AI-generated components; ordered a response to show cause why sanctions such as referral to the Florida Bar should not issue. The filings' problem was not fabricated law: the opinion says it “has nothing to do with hallucinated law or false legal citations.” |
| Order, Oct. 21 | Referred the matter to the Florida Bar. Noted that the response acknowledges a lengthy false quotation, attributed to a case from the same court, in a motion filed below. |
The new fact is the false quotation. In the court's words: “Until AI, and until this case, we never encountered lawyers “hallucinating” non-existent quotations.” Counsel's position, quoted by the court: “Every word I file is a word I have read, judged, verified against its source, and adopted as my own, with the technological competence the same opinion requires.” The court's reply: “A lawyer taking responsibility for a pleading she signed does not relieve the lawyer of responsibility for the pleading’s contents.”
Timeline from the court documents
Dates are the ones the opinion and the order state. Each entry names the document and the PDF page.
- 41-page application filed in the trial court
Counsel for the petitioner files a 41-page document titled "Urgent Omnibus Application" in the Broward County dissolution case, requesting 13 forms of relief, days before a hearing set for July 14.
Opinion of Sept. 16, page 3 - Contempt hearing
The trial court holds the petitioner in contempt and awards fees and costs as a compensatory sanction. Counsel did not move to disqualify the judge at any point during the hearing, the appellate court later finds.
Opinion of Sept. 16, page 4 - 33-page motion to disqualify the judge
Three days after the hearing, a 33-page motion to disqualify the judge is filed. The trial court denies it as legally insufficient.
Opinion of Sept. 16, page 4 - Petition for writ of prohibition
A 61-page emergency petition asks the Fourth District Court of Appeal for a writ of prohibition against the denial of the motion to disqualify and for certiorari review of seven other rulings.
Opinion of Sept. 16, page 4 - Petition denied; order to show cause
The court denies the petition and writes "solely to address counsel's filing of what appears to be 'AI slop.'" A footnote says the problem it addresses "has nothing to do with hallucinated law or false legal citations." It orders counsel to show cause within ten days, without the use of AI, why sanctions, such as referral to the Florida Bar, should not be imposed for submitting frivolous filings.
Opinion of Sept. 16, page 15 - Order: referral to the Florida Bar
On the 82-page response, the court writes that it "misses the point," that the response "does not deny using AI but evades the issue," and that it refers the matter to the Florida Bar. The order carries the line: "Not final until disposition of timely-filed motion for rehearing."
Order of Oct. 21, page 1
Each figure in the October 21 order, with the exact words
| Figure | Exact text | Page |
|---|---|---|
| 2 pages | “On Order to Show Cause” | 1 |
| 82 pages | “Counsel has filed an 82-page response that misses the point.” | 1 |
| Referral | “We refer this matter to the Florida Bar” | 1 |
| Pages 78 and 79 | “At pages 78 and 79 of the response, counsel acknowledges that the motion to disqualify that she filed below contains a lengthy false quotation that she attributed to a case from this Court.” | 2 |
| 9 other participants, 61 misspellings | “The response acknowledges that the rough transcript misspelled the names of nine other participants at the hearing with 61 misspellings altogether.” | 2 |
| Finality | “Not final until disposition of timely-filed motion for rehearing.” | 2 |
Also in the order: “The response does not deny using AI but evades the issue and attempts to defend the frivolous arguments discussed in our prior opinion.”
Read next
For what a referral or sanctions inquiry can mean for a firm's filing process, see what happens if AI hallucinates in a court filing on aivortex.io. A decision from a different forum that addressed non-existent citations: GAO B-424244 (May 12, 2026). The older anchor case: Mata v. Avianca.
Before you rely on this
This page summarizes two court documents; it is not legal advice. Read the order and the opinion themselves before citing them. The corpus record for this case is derived from a third-party database and describes the September 16 opinion; the October 21 content above comes from the order itself.
Primary sources (read October 22, 2026)
Questions this page answers
- What did the Florida 4th DCA order in Lisandrillo v. Palozzi say?
- On October 21, 2026 the court wrote that the 82-page response to its order to show cause "misses the point," that it "does not deny using AI but evades the issue," and that it refers the matter to the Florida Bar. The order is two pages.
- Is the Lisandrillo v. Palozzi order final?
- The order's last line reads: "Not final until disposition of timely-filed motion for rehearing." A rehearing motion would be filed on the docket of No. 4D2026-2262, not in the order, so check that docket before treating the referral as final.
- Did the court say which AI tool was used?
- No. The order says the response does not deny using AI. It does not name a tool or describe how one was used. The September 16 opinion says the court suspected AI-generated components and that its concern "has nothing to do with hallucinated law or false legal citations."
- What changed between the September 16 opinion and the October 21 order?
- On September 16 the court denied the petition and ordered counsel to show cause why sanctions, such as referral to the Florida Bar, should not be imposed. On October 21 it referred the matter to the Florida Bar and noted that the response acknowledged a lengthy false quotation, attributed to a case from the same court, in a motion filed below. The response called it "human error" from drafting under "time pressure."
- Was a monetary sanction imposed in Lisandrillo v. Palozzi?
- The two-page order of October 21, 2026 states no monetary amount. Its operative words are the referral to the Florida Bar. The corpus record describes the September 16 opinion, whose outcome is an order to show cause.