Clerk of the Court and Comptroller for the 13th Judicial Circuit, Hillsborough County, Florida v. Rangel
District Court of Appeal of Florida, Second District · Fla. 2d DCA · Florida bar guidance
Verified May 5, 2026
- Citation
- Clerk of the Ct. v. Rangel, No. 2D2024-1772, 2025 Fla. App. LEXIS 6597 (Fla. 2d DCA Aug. 29, 2025)
- Decided
- August 29, 2025
Summary
Attorney J. Tony Lopez of Taino Law Group filed an answer brief on behalf of appellee Angie Rangel that contained one non-existent case citation, fictitious block quotations attributed to fourteen real cases, and misstated holdings in nine cases. Lopez admitted he hired an independent contractor paralegal to draft the brief, did not review the cited authority before filing, and did not read the appellant's reply brief identifying the errors until the court issued an order to show cause. The per curiam panel (Lucas, C.J., and Silberman and Villanti, JJ.) referred the matter to The Florida Bar.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The court referred Mr. Lopez to The Florida Bar for disciplinary proceedings and sanctions deemed proper, and granted his request to file an amended answer brief with oral argument continued so as not to prejudice his client. No monetary sanction was imposed by the appellate court itself.
Why does Clerk of the Court and Comptroller for the 13th Judicial Circuit, Hillsborough County, Florida v. Rangel matter for law firms using AI?
Rangel is a useful escalation point for managing partners: the Second District did not impose its own monetary sanction but instead routed a Florida Bar referral over conduct that, on the facts, looks identical to the AI-hallucination pattern seen in federal sanctions orders. The court framed the lesson in supervision and competence terms, holding that delegating drafting to a paralegal (or, by clear implication, to a generative AI tool) does not displace the signing attorney’s duty to verify every cited authority before filing.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- The opinion does not expressly name a generative AI tool; the court's closing discussion of "the dangers of relying on generative artificial intelligence" and citation to AI-hallucination precedents strongly imply AI-generated drafting by the contractor paralegal, but the order attributes the fabrications to the paralegal's draft without naming a specific tool.