The decisions
- Lisandrillo v. Palozzi (4th DCA, September 16, 2026) — Fourth DCA says citation-checking alone is insufficient; red flags such as false emergency labels, issue churning, record-contradicted disqualification claims and rough-draft transcripts can trigger show-cause orders and Bar referral. Read it →
- Sean Ryan v. Alina Perez (3rd DCA, September 23, 2026) — Third DCA holds pro se parties to attorneys' citation standards, treats Bar membership as an aggravator, warns future unverified citations will draw sanctions, and denied leave to correct. Read it →
- Kathleen M. Bonczyk v. Richard C. Wolfe (3rd DCA, September 16, 2026) — Third DCA confirms that, after Spencer notice, it may bar a licensed attorney litigating pro se from further pro se filings and refer the order to The Florida Bar. Read it →
The practical upshot
- Verify every citation and record assertion before filing. Courts now expect more than citation-checking, and unverified AI output can prompt show-cause orders and Bar referrals.
- Lawyers representing themselves are held to full standards. Bar membership aggravates fake-citation violations, and repeated meritless pro se filings can yield filing bars plus Bar referral.
- When opposing a suspect brief, catalog each hallucinated citation and link it to the core arguments. Belated corrected-brief requests that lack an explanation may be denied.
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