FL 15th Circuit (Palm Beach): Fifteenth Judicial Circuit (Palm Beach) Administrative Orde…
Chief Judge Glenn D. Kelley · Fifteenth Judicial Circuit of Florida (Palm Beach County)
Verified April 27, 2026
- Citation
- Fifteenth Judicial Circuit (Palm Beach) Administrative Order 2.109-4/26: Use of AI in Court Filings
- Order date
- April 10, 2026
Summary
Any attorney or self-represented litigant who uses any generative AI tool in the preparation of a pleading, motion, memorandum, response, proposed order, or other court document must disclose such use on the face of the filing.
What does the order require?
- Any attorney or self-represented litigant who uses any generative AI tool in the preparation of a pleading, motion, memorandum, response, proposed order, or other court document must disclose such use on the face of the filing.
- The order distinguishes 'Generative AI' (must be disclosed) from 'Traditional AI' such as Westlaw Precision, LexisNexis, and spell-check (no disclosure required).
- Required certification: 'Generative artificial intelligence (name of generative AI program used) was used in the preparation of this filing. The undersigned certifies that all factual assertions, legal authority, and citations have been independently reviewed and verified for accuracy and accepts full responsibility for the contents of this filing.'
- AI-generated notes and recordings are not an official court record and require advance notice to the presiding judge.
- Sanctions parallel the Eleventh Circuit framework: striking the filing, denial of relief, monetary sanctions, contempt, and referral to The Florida Bar.
Practice areas: state civil, state criminal, state family, state probate
What the order requires
Chief Judge Glenn D. Kelley of Florida’s Fifteenth Judicial Circuit (Palm Beach County) signed Administrative Order 2.109-4/26 on April 10, 2026. The order is the most lawyer-friendly of the three Florida circuit AI orders because it expressly carves out traditional AI tools (legal research platforms, spell-check) from the disclosure requirement.
- Disclosure on the face of the filing. Any use of generative AI must be disclosed on the face of the filing.
- Generative vs. Traditional AI distinction. Westlaw Precision, LexisNexis, spell-check, and similar pre-existing legal-research and word-processing tools are classified as “Traditional AI” and do not require disclosure. Only generative AI use triggers the disclosure-and-certification requirement.
- Tool identification within certification. The required certification names the specific generative AI program inline (in parentheses).
- AI notes and recordings. AI-generated notes and recordings are not an official court record and require advance notice to the presiding judge.
- Sanctions toolkit. Mirrors the Eleventh Circuit framework.
Why the Traditional AI carve-out matters
Several federal AI standing orders are silent on whether AI features now embedded in legal-research platforms (Westlaw GenAI, Lexis Protégé, Microsoft 365 Copilot) require disclosure. The Fifteenth Circuit takes a position: traditional research and productivity tools, including their AI features marketed under existing platform names, do not trigger disclosure. Generative drafting tools (ChatGPT, Claude, Gemini, etc.) do.
The order’s text is not perfectly precise about where the line falls within a single platform. Westlaw’s AI Assistant generative drafting feature, for example, is arguably both “Traditional AI” (because it is part of Westlaw) and “Generative AI” (because it generates new content). Practitioners should disclose conservatively when using generative drafting features within research platforms, even if the platform brand is on the Traditional AI side of the order’s examples.
Practitioner workflow
For Palm Beach matters, the disclosure block is required only when generative AI is used. Firms running Westlaw Precision searches and using spell-check do not need to file disclosures for those tools. Firms using ChatGPT, Claude, or generative drafting features in any platform should file disclosures and use the prescribed certification language with the specific tool name parenthesized.
Scope
Fifteenth Judicial Circuit only (Palm Beach County). For neighboring Florida circuits, see Eleventh Circuit AO 26-04 (Miami-Dade) and Seventeenth Circuit AO 2026-03-Gen (Broward).
Primary source
AO 2.109-4/26 (PDF): https://www.15thcircuit.com/sites/default/files/administrative-orders/2.109.pdf