On September 16, 2026, Florida's Fourth District Court of Appeal issued a show-cause order in Lisandrillo v. Palozzi requiring counsel to explain her filings — without using AI. The court described the submissions as containing "gibberish," abusing the litigation process, and bearing "indicia of non-human authorship." Coverage of the order ran the same week in legal media.
If you are a solo attorney or small firm owner, this order is worth reading carefully. Not because it proves AI is dangerous. And not because it is simply a story about user error. It is a story about workflow design — and that distinction is exactly what solo practitioners need to hear.
What the court actually objected to
The court did not object to AI. It objected to filings that apparently no human read before they went out the door.
That distinction matters more than most of the commentary on this story acknowledges. The dominant takes are either "see, AI is dangerous" or "this was pure negligence." Both miss the more useful point: the problem was not the tool. The problem was that the tool was treated as a replacement for professional judgment rather than an input to it. AI-generated text moved from draft to filing without a human verifying citations, reading paragraphs, and confirming the argument made sense.
When a brief contains "gibberish," that is not an AI failure. That is a quality control failure. The signature on the filing was still a lawyer's.
The honest tension for solo and small firms
Here is the part nobody wants to say out loud. The firms that most need the leverage AI offers — competing against larger staffs, longer research hours, and bigger budgets — are also the ones with the least bandwidth to double-check output.
A large firm can put a second attorney on every brief. A solo practitioner often cannot. So the verification step that everyone agrees is necessary has to fit into a workflow that already has no spare hours in it.
That is the real risk. Not that solo attorneys are careless, but that the verification step lives as an intention rather than a process. Good intentions do not catch a hallucinated citation at eleven the night before a deadline.
What a firm can do this week
A written rule. That is all this takes at the operational level. One sentence that says: no AI output leaves this office without a human checking every citation against the source, reading every paragraph, and confirming that the argument is one the attorney would actually make in court.
Name who owns that step. In a solo practice, that is you. Write it down anyway, because a rule that exists only as an intention is not a rule.
The tool is legitimate. The leverage is real. The verification step is not optional, and it does not get lighter just because the deadline is close.
A note from Attorney Council
Attorney Shawn Council also co-founded legalegal.ai, a platform built specifically for solo attorneys and small firms. His perspective on AI in law comes from both sides of the table — as a practicing attorney and as someone who builds tools for the profession. The position has always been the same: AI is a tool, not a professional. The judgment and the signature belong to the attorney.
This article discusses a recent court order and general practice management considerations. It is not legal advice. Source: Eugene Volokh, The Volokh Conspiracy / Reason, September 18, 2026; underlying order Lisandrillo v. Palozzi, No. 4D2026-2262 (Fla. 4th DCA, Sept. 16, 2026).
This article is provided for general informational purposes only and does not constitute legal advice. Reading this article does not create an attorney-client relationship.