The Volokh Conspiracy

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AI in Court

"AI Slop" Decried by Florida Appellate Court: "Counsel's Lengthy and Unfocused Filings Contain Gibberish"

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From Wednesday's decision by Florida Court of Appeal Justice Gross in Lisandrillo v. Palozzi, joined by Justice Robert Gross, joined by Justices Spencer Levine and Caroline Shepherd:

We deny the extraordinary writ petition seeking review in this dissolution of marriage case and write solely to address counsel's filing of what appears to be "AI slop." Counsel's lengthy and unfocused filings contain gibberish and abuse the litigation process in different ways—including by churning out convoluted, false, and frivolous arguments.

{The AI slop problem we address here has nothing to do with hallucinated law or false legal citations.

The citations are real. The cases exist. The language is confident. Yet the analytical reasoning—or lack of it—reveals that the arguments were assembled by an AI tool rather than developed through a trained advocate's independent judgment.

Jodi Swick & Jarrett Ganer, AI Slop Filings Show Lawyers Must Do More Than Check Citations, Bloomberg Law (January 26, 2026, 4:30 AM). We agree that AI-drafting without meaningful attorney involvement "undermines the very premise of qualified legal representation."}

We suspect that counsel's filings contain AI-generated components. {Ironically, while some of the content appears AI-generated, other portions appear too unpolished to have been produced by AI.} Abusive AI filing threatens the orderly administration of justice. We have recently sanctioned vexatious pro se litigants for abusive AI filings. Courts must require more from attorneys and not tolerate abusive practice fueled by AI….

For more details on why the court thinks "[t]he filings contain indicia of non-human authorship," read the (longish) opinion. Just a few small excerpts:

Legal Gibberish

The allegation in ground H that the judge admonished counsel for not cross-examining witnesses is bizarre. No such citation or quotation of the alleged admonishment is in the record. At paragraph 77, the motion argues:

The Court admonished her for that judgment. The bind that creates, participate and get shut down on the one hand … decline and get admonished on the other, is not a fair proceeding. It is the record of one.

(bold and italics in original).

The filings often emphasize (with bold and italics) seemingly random sentences causing the reader to focus on what turns out to be irrelevant facts.

Here, the motion emphasizes legal gibberish. The motion and petition contain many other puzzling arguments….

[Another set of unfounded claims] typifies the "issue churning" problem. AI churns out a laundry list of convoluted arguments that no competent lawyer should make. Counsel must exercise independent judgment when making arguments to a court.

The unnatural ways the arguments are presented further leads us to suspect AI was used.

Ultimately, however, 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….

Order to Show Cause

Within ten (10) days of this opinion, petitioner's counsel, Jaclyn R. Soroka, shall file a response 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 for submitting frivolous filings to this Court.

Thanks to Griffin Klema for the pointer.