LORIE JEAN LISANDRILLO v. RENEE PALOZZI (2026)

On Order to Show Cause

In Lisandrillo v. Palozzi, No. 4D2026-2262, 2026 WL 2727559 (Fla. 4th DCA Sept. 16, 2026), we denied the petition in this case and issued an order to show cause why counsel for petitioner should not be sanctioned for frivolous filing. Counsel has filed an 82-page response that misses the point. No competent attorney, much less one who holds herself out as board certified, should file a similar petition in an appellate court.

We refer this matter to the Florida Bar and write only to mention a few observations.

The response does not deny using AI but evades the issue and attempts to defend the frivolous arguments discussed in our prior opinion. Counsel insists that she used independent judgment and did not delegate her duties as a lawyer to AI: “Every word I file is a word I have read, judged, verified against its source, and adopted as my own, with the technological competence the same opinion requires.” A lawyer taking responsibility for a pleading she signed does not relieve the lawyer of responsibility for the pleading's contents.

Some of counsel's statements should be mentioned. At pages 78 and 79 of the response, counsel acknowledges that the motion to disqualify that she filed below contains a lengthy false quotation that she attributed to a case from this Court. Counsel claims this was “human error” from drafting under “time pressure.” Until AI, and until this case, we never encountered lawyers “hallucinating” non-existent quotations.

As for the frivolous argument that the judge allegedly mocked counsel by mispronouncing her name, counsel defends this claim as supported by misspellings of her name in the unofficial rough transcript of the hearing. The response acknowledges that the rough transcript misspelled the names of nine other participants at the hearing with 61 misspellings altogether. Counsel's name was misspelled nine times. The guardian ad litem's name was misspelled 24 times, and the names of opposing counsel and respondent were also misspelled many times. Counsel insists that she used independent judgment and vetted every word of her filings. Thus, counsel appears to acknowledge that she intentionally brought a false claim that she was mocked based upon the obvious typographical errors in an unofficial transcript. Counsel also insists, contrary to the transcript, that the judge prevented her from moving to disqualify during the hearing.

That counsel believes her practice in this case is acceptable raises many issues that the Florida Bar should consider.

Matter referred to the Florida Bar.

Per Curiam.

Gross, Levine and Shepherd, JJ., concur.