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 October 1, 2026
- Citation
- Fifteenth Judicial Circuit (Palm Beach) Administrative Order 2.109-4/26: Use of AI in Court Filings
- Order date
- April 10, 2026
Status and former requirement
No longer in force (rescinded); this order does not state current filing practice. While it was operative it required: 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 the order required while in force
- 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
No longer in force
This order was vacated in its entirety effective 2026-06-15 by AO 2.109-5/26, signed 2026-05-29. Florida Rule of General Practice and Judicial Administration 2.515(d)(2), effective 2026-06-15, now governs filings statewide, and companion order AOSC26-12 bars Florida courts from imposing AI disclosure or certification requirements “whether through local administrative orders, court policies, judicial practices and procedures, or other means.”
Everything below describes what this order required while it was operative. It is retained because filings made in that window are still judged against it. It does not state current practice, and a filing workflow should not be built from it.
What the order required
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 exempts “Traditional AI” (rule-based research tools and spelling and grammar checks) 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. “Traditional AI” (rule-based programs that search and sort legal databases, and spelling and grammar checks) did not have to be disclosed; the order’s examples included Westlaw Precision, LexisNexis, Justia, and FindLaw. Generative AI use, including “legal research using generative AI,” triggered the disclosure-and-certification requirement, and the order’s generative examples included Lexis+AI and the Westlaw drafting assistant.
- Tool identification. The required certification names the generative AI program inline (in parentheses), and the order separately provided that “the document shall identify the specific tool used.”
- 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 embedded in legal-research platforms require disclosure. The Fifteenth Circuit drew the line by function, not by platform: research “utilizing rule-based programs to process, sort and analyze legal databases” was exempt, while “legal research using generative AI” had to be disclosed. Its own examples put a platform’s generative features on the disclosable side: Lexis+AI and the Westlaw drafting assistant are listed as generative AI programs, while Westlaw Precision and LexisNexis appear among the traditional and non-AI research tools.
That question no longer arises: the order is vacated and Rule 2.515(d)(2) imposes no disclosure duty, so this section is kept only to explain how the carve-out operated.
Practitioner workflow while the order was in force
While the order was operative, the disclosure block was required for Palm Beach matters only when generative AI was used. Rule-based research and spell-check did not trigger it; ChatGPT, Claude, or generative features in any platform, including generative research, did, and the prescribed certification named the specific tool parenthetically. Rule 2.515(d)(2) supersedes all of that: there is no disclosure duty and no tool to name.
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
The circuit reuses the same 2.109.pdf path for each revision, so the live URL now serves the vacating order rather than the AI order described on this page. Both are listed, labelled for what they actually return.
- AO 2.109-4/26, the AI order (Internet Archive capture, 2026-05-20). Captured between the order’s 2026-04-10 issuance and its 2026-05-29 vacatur; carries the caption “ADMINISTRATIVE ORDER NO. 2.109-4/26, IN RE: DISCLOSURE OF USE OF GENERATIVE ARTIFICIAL INTELLIGENCE BY ATTORNEYS AND SELF-REPRESENTED LITIGANTS.”
- AO 2.109-5/26, the vacating order (live circuit path)
How this order changed
Dated record of this order's own lifecycle. Where it was amended or withdrawn, the badge shows its standing after that step.
- activeSigned by Chief Judge Glenn D. Kelley, requiring disclosure of generative AI use on the face of the filing and a certification naming the program and stating that the filing was independently reviewed, while exempting 'Traditional AI' such as rule-based research tools and spelling and grammar checks. source
- Chief Judge Kelley signed AO 2.109-5/26, vacating AO 2.109-4/26 in its entirety effective June 15, 2026 at 12:01 a.m. and stating that 'Local Administrative Orders relating to AI disclosure are now preempted.' source
- rescindedThe vacatur by AO 2.109-5/26 took effect at 12:01 a.m., the moment amended Rule 2.515(d)(2) took effect statewide. source