Lisandrillo v. Palozzi
The Fourth DCA denied a 61-page "emergency" prohibition petition challenging denial of a motion to disqualify (and purporting to seek certiorari review of seven additional rulings) in a dissolution case, and issued an order to show cause why counsel should not be sanctioned or referred to The Florida Bar. The court cataloged the hallmarks of what it called "AI slop" — abusive emergency designations, issue churning, arguments contrary to the record, citation to an unpublished order, and the recurring false claim that filing a rule 2.330 disqualification motion automatically stays proceedings — and held that courts must demand more from attorneys than mere citation-checking.
Key facts
- Lisandrillo sought to disqualify the judge in a dissolution case by filing a prohibition petition; the trial court denied the disqualification motion, and Lisandrillo's counsel filed a 61-page emergency prohibition petition that also attempted to seek certiorari review of seven additional non-final rulings.
- The petition contained multiple deficiencies, including abusive emergency designation without imminent irreparable harm, arguments contradicted by the hearing transcript, citations to unpublished orders, and repeated false claims that filing a rule 2.330 motion automatically stays proceedings.
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Why it matters
This is the Fourth DCA's most detailed treatment yet of attorney (as opposed to pro se) misuse of generative AI, and it extends the court's earlier Avery and Gouldy sanctions line to licensed counsel. Litigators should… — full analysis with a trial
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