Rodriguez v. Rodriguez
Florida Sixth District Court of Appeal · Fla. 6th DCA · Florida bar guidance
Verified September 30, 2026
- Citation
- Rodriguez v. Rodriguez, No. 6D2025-3086, 2026 WL 969721 (Fla. 6th DCA Apr. 10, 2026)
- Filing date
- April 10, 2026
Summary
Attorney Karin S. Gerardin of Gerardin Law Firm, P.A. in Tavares filed a petition for writ of certiorari on behalf of Bruno Roberto Rodriguez challenging an Orange County Circuit Court order in a dissolution proceeding against Kathryn Louise Rodriguez. The Sixth District Court of Appeal dismissed the petition and noted that it cited non-existent cases as well as actual cases that did not stand for the legal propositions asserted. The court found the petition appeared to have been produced with the assistance of generative artificial intelligence without sufficient guardrails to ensure accuracy.
- AI tool:
- Unspecified generative AI
What is the current procedural posture?
The court dismissed the petition and ordered Ms. Gerardin to show cause within ten days why she should not be sanctioned for filing a petition containing fabricated and misrepresented citations, and why she should not be referred to the Florida Bar for potential discipline. No monetary sanction was imposed in this order.
Why does Rodriguez v. Rodriguez matter for law firms using AI?
Rodriguez is a state appellate-court counterpart to the federal AI-citation sanctions docket and a useful data point for Florida managing partners: the Sixth DCA escalated directly to a show-cause order and a potential Florida Bar referral for an attorney whose petition cited fabricated authority, without waiting for opposing counsel to surface the problem. The order signals that Florida appellate panels are now reviewing citations for AI-era authenticity defects and treating them as candidates for discipline rather than mere briefing errors.
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.
- Panel composition not extracted from PDF text.
- Whether the show-cause order has been ruled on is unknown: the Sixth District's ACIS docket for 6D2025-3086 is not publicly accessible (the public API returns caseAccess false for this certiorari proceeding, checked 2026-09-30), and no later order was located. The entry stays pending until the outcome can be confirmed, which would take a clerk request.