Jaclyn Soroka Referred to Florida Bar Over AI Court Filings

Jaclyn R. Soroka has been referred to the Florida Bar for possible disciplinary proceedings after an appeals court criticised filings that it said showed characteristics associated with the misuse of generative artificial intelligence.

The Florida Fourth District Court of Appeal made the referral after considering Soroka's response to an earlier order requiring her to explain why she should not face sanctions over filings made in a family law dispute.

The court had previously criticised her submissions as lengthy, unfocused and containing what it described as "AI slop". Unlike cases involving lawyers submitting fictitious authorities generated by generative artificial intelligence, the court's original concerns were not based on hallucinated law or false legal citations. Instead, it questioned the reasoning and professional judgment behind the arguments.

Soroka did not deny using AI in her response to the court but maintained that she had exercised independent professional judgment and verified the material she submitted. The appeals court said taking responsibility for a signed pleading did not relieve a lawyer of responsibility for its contents.

The proceedings arose from Lisandrillo v. Palozzi, a dissolution of marriage dispute in which Soroka represented petitioner Lorie Jean Lisandrillo. In September, the appeals court denied a petition seeking extraordinary relief and ordered Soroka to show cause why she should not be sanctioned for a frivolous filing.

Soroka subsequently submitted an 82-page response to the show-cause order. The appeals court said the response missed the point and attempted to defend arguments it had previously characterised as frivolous.

The court also identified a lengthy false quotation attributed to one of its previous cases in a motion filed in the lower court. Soroka acknowledged that the quotation was incorrect but attributed the error to human error while drafting under time pressure.

The October ruling also revisited an allegation that the trial judge had mocked Soroka by mispronouncing her name. The appeals court pointed to numerous misspellings of several participants' names in an unofficial rough transcript and questioned Soroka's continued reliance on those errors to support the allegation.

The referral comes as Florida courts increase scrutiny of lawyers' use of generative AI. Earlier this year, the Florida Supreme Court amended statewide rules governing court filings to require signatories to ensure that identified legal authorities exist and are accurately cited. Courts may impose sanctions when filings fail to meet that requirement.

The Soroka case potentially extends the professional risks beyond the increasingly familiar problem of fabricated AI authorities. Even where cited cases exist, lawyers may face scrutiny when technology-assisted drafting produces arguments that a court considers frivolous or lacking the independent legal analysis expected from counsel.

That distinction is significant for law firms developing policies around generative AI. Citation verification remains essential, but the Fourth District's decisions demonstrate that checking whether authorities exist does not replace a lawyer's responsibility for the reasoning, relevance and quality of a submission.

The Florida Bar will now have responsibility for considering the referral and determining whether disciplinary proceedings should follow. The referral itself is not a disciplinary finding by the Bar, but the case provides another indication that judicial scrutiny of lawyers' AI use is moving beyond fabricated citations to the quality of AI-assisted legal reasoning itself.