A lawyer can accept responsibility for a filing and still fail to explain why its contents were professionally defensible.
Florida’s Fourth District Court of Appeal made that point in an October 21 order referring Jaclyn Soroka to the Florida Bar after an 82-page response to its show-cause order.
The panel said the response did not deny AI use and continued defending arguments the court considered frivolous. It also identified a lengthy false quotation attributed to one of its decisions. Florida Fourth DCA: Lisandrillo v. Palozzi order, reproduced by Justia.
The order and the lawyer’s response
Soroka maintained that she had exercised independent judgment and verified her submissions. She attributed the quotation error to human drafting under time pressure. The court found her explanation inadequate.
The referral is for the Bar’s consideration, not a final disciplinary finding. The order also states that it remains subject to disposition of a timely rehearing motion. Florida Fourth DCA: Lisandrillo v. Palozzi order, reproduced by Justia.
The case makes an important distinction for firms developing AI-review procedures. Confirming that a cited decision exists does not establish that a quotation is accurate, that the decision supports the proposition or that the argument belongs in the filing.
Verification must reach the reasoning
Review must reach the reasoning.
That means asking whether the submission addresses the governing test, connects the record to the requested remedy and excludes assertions the evidence cannot support. Length should also receive substantive attention: additional pages can conceal the absence of a coherent argument.
For Canadian practitioners, the Florida order is a comparative professional-conduct development. It does not establish a new Canadian filing requirement.
Responsibility for the filed work
Its practical relevance is nevertheless immediate. A firm’s assurance that a lawyer “reviewed the output” says little unless the review includes source verification, factual assessment and legal judgment.
The court’s concern ultimately attaches to the work submitted. The precise contribution of a particular drafting tool does not answer whether that work meets professional standards.
A verified citation is one checkpoint. A defensible argument is the responsibility.
Related coverage: B.C. Court Warns That Poor AI Filings Can Undermine Access to Justice · Judge Declines Sanctions Over AI Errors, Raises Junior Lawyer Training Concerns.
Sources: Florida Fourth DCA: Lisandrillo v. Palozzi order, reproduced by Justia .
