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

From Wednesday's decision by Florida Court of Appeal Judge Robert Gross in Lisandrillo v. Palozzi, joined by Judges 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.

UPDATE 10/2/2026 1:02 pm: Here's the lawyer's response to the Order to Show Cause; her office passes along the following comments:

From the public record: no sanction has been imposed; the order is a show cause order, and the response asks that it be discharged (p. 82). The opinion's first footnote states that the problem it addresses has nothing to do with hallucinated law or false legal citations (quoted in the response at pp. 4 and 77). The response reviews every citation in the four filings the opinion describes, about 237, and reports two errors, both in the motion to disqualify, which it corrects and describes as "the human errors of a lawyer drafting from earlier pleadings under time pressure" (pp. 78 to 79). Ms. Soroka's practice with respect to technology is stated at pages 2 to 3. She represented her client in the appellate court pro bono (pp. 6, 26, 72; and see p. 7)….

In her own words, from the response:

"Suspicion can be formed from the way something looks; authenticity can only be taken from the source. In this Court the source is the record, and the authenticity of my filings is established by it, not by suspicion." (p. 2)

"The mere fact that my client could not pay me bears no relation to the quality of my work, and any inference otherwise would be mistaken. I worked at my highest capacity on this matter, irrespective of compensation, because it was the right thing to do; the reward for that work was felt, not deposited." (p. 7)

"[W]ords placed in a public forum carry a permanent digital footprint, and I pray that our profession does better than this, because no one deserves to be placed in a category called slop without the authentic source set beside it." (p. 80)