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Florida appeals court refers divorce lawyer Jaclyn Soroka to Florida Bar over AI-generated filings

Published
Score
15

Why it matters

Florida's Fourth District Court of Appeal referred divorce attorney Jaclyn Soroka to the Florida Bar on October 21, 2026. The court rejected her response to a possible sanctions order and said her filings read like those of a vexatious pro se litigant. Law360 reported that the filings included AI-hallucinated quotations, and Soroka acknowledged one false quote, which she blamed on human error and time pressure. The referral follows a months-long dispute. On September 16, the court denied her petition for a writ of prohibition, then ordered her to show cause why sanctions should not be imposed and criticized the length and focus of her filings.

Several points remain open. Reporting on the ruling is inconsistent. Reuters described the filings as bearing the hallmarks of generative AI output and called them "AI slop." Volokh Conspiracy noted that the opinion's first footnote says the problem it addresses has nothing to do with hallucinated law. Volokh also reported that the show-cause order asked Soroka to respond without using AI and that the order was not itself a sanction. Soroka disputes the court's criticism and says she used her own legal judgment and checked her sources. No sanction has been announced, and the scope of the Bar referral has not been made public.

The ruling fits a broader pattern. In August 2026, the Second District Court of Appeal fined Kenneth H. Keefe $1,500, referred him to the Bar after finding 46 hallucinated authorities in his briefs, and ordered him to personally pay his opponent's fees for responding to those filings. Keefe was a separate case, but it shows the same concern with unverified AI output. For attorneys, the Soroka ruling matters because it extends scrutiny beyond fake citations to the quality of reasoning in AI-assisted filings. The court treats inadequate attorney involvement in drafting as a conduct issue, and a Bar referral carries more consequence than a fine. Florida lawyers using AI should review how the Bar acts on this referral and whether other appellate courts adopt the same standard.

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