FL 19th Circuit (Indian River, Martin, Okeechobee, St. Lucie): Nineteenth Judicial Circui…
Chief Judge Charles A. Schwab · Nineteenth Judicial Circuit of Florida (Indian River, Martin, Okeechobee, and St. Lucie Counties)
Verified October 1, 2026
- Citation
- Nineteenth Judicial Circuit Administrative Order 2025-10: Use of Artificial Intelligence in Court Filings
- Order date
- December 17, 2025
Status and former requirement
No longer in force (rescinded); this order does not state current filing practice. While it was operative it required: Any filing drafted in whole or in part with the assistance of AI technology must contain a clear disclosure on the face of the document specifying AI technology was used (e.g., drafting, editing, citing, cite-checking).
What the order required while in force
- Any filing drafted in whole or in part with the assistance of AI technology must contain a clear disclosure on the face of the document specifying AI technology was used (e.g., drafting, editing, citing, cite-checking).
- Each such filing must also include a certification that the attorney of record (or pro se litigant) has personally reviewed the filing and verified the accuracy of all factual statements, legal arguments, and case citations in substantial conformity with Exhibit A attached hereto.
- Sample disclosure language: [TITLE OF DOCUMENT TO BE FILED] (AI was used in the preparation and/or generation of this document.)
- Attorneys remain fully responsible for their work product and must comply with all obligations under the Rules Regulating The Florida Bar, including but not limited to Rule 4-1.1 (Competence), Rule 4-1.6 (Confidentiality), Rule 4-3.3 (Candor to Tribunal), Rule 4-5.1 (Supervision), and Rule 4-5.3 (Nonlawyer Supervision).
- Sanctions for non-compliance may include striking pleadings, filings, or dismissing actions; monetary fines; imposition of attorneys' fees and costs; contempt sanctions; mandatory continuing legal education in ethics or technology; referral to The Florida Bar for disciplinary proceedings.
- This Order applies equally to pro se litigants.
Practice areas: state civil, state criminal, state family, state probate
No longer in force
This order was rescinded effective 2026-06-15 by AO 2026-06, signed 2026-06-16. 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 Charles A. Schwab of Florida’s Nineteenth Judicial Circuit signed Administrative Order 2025-10 on December 17, 2025, effective the same day. The order brings the 19th Circuit (Indian River, Martin, Okeechobee, and St. Lucie Counties) into line with the Florida circuit-court trend of disclosure-plus-certification AI orders.
- Disclosure on the face of the filing. Any filing drafted in whole or in part with AI must include a face-of-the-document disclosure naming the function (drafting, editing, citing, cite-checking).
- Certification. Each AI-assisted filing must also include a certification that the attorney or pro se filer has personally reviewed the filing and verified the accuracy of all factual statements, legal arguments, and case citations.
- Required certification text. Exhibit A prescribes a four-paragraph certification beginning “I hereby certify that I am the attorney of record or pro se party in this matter.”
- Florida Bar Rules cross-referenced. Order paragraph 3 explicitly invokes Rules 4-1.1 (Competence), 4-1.6 (Confidentiality), 4-3.3 (Candor to Tribunal), 4-5.1 (Supervision), and 4-5.3 (Nonlawyer Supervision).
- Sanctions toolkit. Striking filings, dismissal, monetary fines, attorneys’ fees, contempt, mandatory CLE, referral to The Florida Bar.
- Pro se equally bound. A dedicated paragraph confirms the order applies equally to pro se litigants.
Notable distinctions from sister Florida circuits
The 19th Circuit’s order had two notable features compared to the 11th, 15th, and 17th Circuit orders:
- Whereas-clause guidance for pro se litigants. Unique among Florida circuit AI orders, AO 2025-10 includes a whereas clause specifically warning that pro se litigants who use AI “must be aware of the technology’s ability to generate outputs containing fictitious and unfounded legal arguments and/or citations to legal authority” and must ensure such content does not appear in filings.
- Broader “AI technology” framing. The disclosure trigger is “AI technology” generally, not “generative AI” specifically (though the certification refers to “generative artificial intelligence (AI) technology”). While the order applied, the safe reading was to disclose whenever any AI tool had been used in any phase of drafting.
Practitioner workflow while the order was in force
While AO 2025-10 applied, firms with matters in Indian River, Martin, Okeechobee, or St. Lucie counties built the Exhibit A certification into their filing templates: the disclosure was a single sample-language line on the cover page, the certification a separate block tied to the signature page, and pro se clients were advised in writing that the order reached them. None of that is required now. Filings in the 19th Circuit are governed by Rule 2.515(d)(2), and a filing made while the order was in force is still judged against it.
Scope
Nineteenth Judicial Circuit only (Indian River, Martin, Okeechobee, and St. Lucie Counties). For neighboring Florida circuits, see Eleventh Circuit AO 26-04 (Miami-Dade), Fifteenth Circuit AO 2.109-4/26 (Palm Beach), and Seventeenth Circuit AO 2026-03-Gen (Broward).
Primary source
Administrative Order 2025-10 (PDF): https://www.circuit19.org/wp-content/uploads/2025/09/2025-10.pdf
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 Charles A. Schwab and effective the same day, requiring a face-of-document disclosure on any filing drafted with AI assistance and an Exhibit A certification of personal review and verification of factual statements, legal arguments, and case citations. source
- rescindedRescinded effective 12:01 a.m. by AO 2026-06, which Chief Judge Schwab signed the next day, following AOSC26-12 and amended Rule 2.515(d)(2). source
- Chief Judge Schwab signed AO 2026-06, rescinding AO 2025-10 effective the previous day, June 15, 2026 at 12:01 a.m. source