U.S. District Court Middle District of Florida issues standing order requiring disclosure of artificial intelligence use in all filings
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Judge Anne-Leigh Gaylord Moe has mandated that every filer in the Ramskog v. Parks Automotive Group case must certify under penalty of perjury whether AI was used to prepare their documents.
Judge Anne-Leigh Gaylord Moe of the U.S. District Court for the Middle District of Florida issued a standing order on August 20, 2026, requiring an affirmative disclosure of artificial intelligence use for every filing in a pending case. The order, first reported by CourtListener, applies to the matter of Ramskog v. Parks Automotive Group, Inc. It forces every filer, whether they're a licensed attorney or representing themselves, to include a specific certification regarding the use of AI tools in their document preparation. ## The Asymmetric Cost of AI Hallucinations
Judge Moe's order targets the specific risk of AI generating filings that rely on non-existent cases or arguments that don't support the claims being made. The court describes the cost of these automated errors as "asymmetric." While the filing is easy for a party to generate, it forces taxpayers to fund the court's effort to verify citations that may not exist. If the court spends its finite resources only to find that a cited case is fake, the order warns that sanctions may be entered under Rule 11 of the Federal Rules of Civil Procedure. These sanctions are intended to exceed the cost of the legal research the filer failed to perform. ## Strict Disclosure Requirements
The court isn't interested in "substantial compliance." The order demands verbatim use of two specific certification forms. One for when AI wasn't used, and one for when it was. Any filing that misses these exact statements can be stricken from the record. If the filing is a motion or complaint, the court may deny the requested relief without prejudice. The order defines a clear line between AI and traditional digital tools. Filers don't need to disclose the use of Westlaw, LexisNexis, or standard search engines like Google, Brave, DuckDuckGo, Yahoo, or Bing. Everything else is fair game. ## Resolving Doubts Against the Filer
If a filer is unsure if their tool counts as AI, the court's instruction is simple: disclose it. The order states that every doubt should be resolved in favor of disclosure. The certification for AI use requires the filer to insert a description of exactly how the technology was utilized. The mandate serves as a reminder that Rule 11 obligations are "inescapable." It requires filers to certify, under penalty of perjury, that they have personally read every case cited in their filing. For attorneys, the stakes are higher. The order notes that citing non-existent cases may be treated as a violation of the oath of candor toward the tribunal. This could lead to the revocation or suspension of their admission to practice in the Middle District of Florida. Any filer, lawyer or not, could face a referral for criminal prosecution if they provide a false certification.