Lisandrillo v. Palozzi — Florida appeals court referred petitioner’s counsel to the Florida Bar over a frivolous filing and false quotation

Case
Lorie Jean Lisandrillo v. Renee Palozzi
Court
Florida Fourth District Court of Appeal
Judge
Gross; Levine; Shepherd
Date Decided
October 21, 2026
Docket No.
4D2026-2262
Topics
Attorney Discipline, Frivolous Filings, Professional Responsibility
Source
Read the full opinion

Background

The Fourth District previously denied Lorie Jean Lisandrillo’s petition for a writ of prohibition and ordered her counsel to show cause why counsel should not be sanctioned for a frivolous filing. Counsel submitted an 82-page response defending the arguments addressed in the court’s prior opinion and asserting that she had independently reviewed, verified, and adopted every word filed.

The court observed that the response did not deny using artificial intelligence but evaded that issue. It also noted counsel’s acknowledgment that a motion to disqualify filed in the trial court contained a lengthy false quotation attributed to a Fourth District case. Counsel characterized the quotation as human error caused by time pressure.

The court further criticized counsel’s claim that the trial judge mocked her by mispronouncing her name. That claim relied on misspellings in an unofficial rough transcript that also misspelled nine other participants’ names 61 times in total. The court said counsel appeared to acknowledge intentionally advancing a false claim based on obvious typographical errors and also maintained, contrary to the transcript, that the judge prevented her from moving to disqualify during the hearing.

The Court’s Holding

The Fourth District referred the matter to the Florida Bar. It concluded that counsel’s defense of her conduct raised issues warranting the Bar’s consideration and emphasized that accepting responsibility for a signed filing does not relieve a lawyer of responsibility for its contents.

The court did not find that counsel used artificial intelligence. It stated only that counsel did not deny using AI and evaded the issue. Its referral rested on the concerns identified in counsel’s filings and response, including the frivolous arguments, the single lengthy false quotation, and the claim of judicial mockery based on obvious errors in an unofficial transcript.

Key Takeaways

  • A lawyer’s assertion that she reviewed and adopted every word of a filing does not excuse false or frivolous content.
  • The court identified one lengthy false quotation attributed to a Fourth District case and rejected counsel’s explanation that it resulted from human error under time pressure.
  • The opinion did not establish that AI was used; it said counsel did not deny using AI and evaded the issue.

Why It Matters

The decision underscores that appellate counsel remain personally accountable for the accuracy and factual basis of signed filings, regardless of the drafting tools or process involved. Reliance on an unofficial transcript’s obvious typographical errors cannot support an accusation that a judge intentionally mocked counsel.

The referral also signals that defending questionable filing practices as acceptable may itself heighten professional-responsibility concerns and prompt scrutiny by attorney disciplinary authorities.

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