A show cause hearing at Florida's Sixth District Court of Appeal, conducted via Zoom and published on YouTube on May 31, 2026, captured something rarely documented in public: a licensed attorney admitting, under direct questioning from three judges, that the argument section of his appellate brief contained no argument of any kind. The 44-minute proceeding, which had garnered 7,879 views within days of upload, has since circulated widely on LinkedIn and other professional networks, sparking a broader debate about what happens to deep knowledge when tools do the thinking.

The hearing and what was said

The case before Judges White, Brownlee, and Mize was Foreman Electric Services, Inc. v. LSQ Funding Group, L.C., case number 6D23-2601, appealed from the Circuit Court for Orange County, where Judge Vincent Falcone III had presided. The Sixth District Court of Appeal - established January 1, 2023, the first new Florida appellate court since 1979 - convened the special session not to rule on the merits of the underlying dispute, but to determine whether sanctions should be imposed against appellant's counsel, Jerome Ramsaran, personally.

The dual basis for potential sanctions was explicit from the opening minutes. The panel cited Florida Rule of Appellate Procedure 9.410(A), which authorises a court to impose penalties for filing any proceeding, motion, brief, or other document that is frivolous or in bad faith, and Section 57.105(1)(B) of the Florida Statutes, which addresses unsupported claims in litigation.

According to the transcript, Ramsaran told the panel that the month of the hearing marked his 10th year in practice. He described his primary area as consumer protection - homeowners insurance claims, personal injury actions against banks and lending institutions, and more recently commercial work including government contracting. He estimated having handled more than 10 but fewer than 20 appeals, and said he had been engaged in appellate work for at least five years.

What followed was an extended, methodical examination of the brief itself.

"No argument at all"

Judge White was the first to name the central problem directly. According to the transcript, the panel's finding was that the argument section of Ramsaran's amended initial brief was "just kind of a cut and paste from various rules and cases with no explanation whatsoever" of how any cited authority applied to the facts of the case or demonstrated that the trial court had erred.

The judge asked a direct question: "Is there any part of your argument section, Mr. Ramsaran, that you can point to and say this made an argument?"

According to the transcript, Ramsaran's response was: "No. No."

That exchange, later shared verbatim on LinkedIn by Robert Freund, an advertising and e-commerce attorney, drew five reactions within hours of posting. Freund's caption - "Lawyer with impostor syndrome? Watch this. This is really unbelievable stuff." - framed what many in professional networks had been discussing in less visible ways: whether the surface-level availability of AI-generated text was producing professionals who could produce documents without understanding their contents.

The judges pressed further. According to the transcript, Ramsaran was asked whether he agreed that his argument section included no argument of any kind. He answered: "Uh yes."

The brief's structural failures, in detail

The panel's critique extended beyond the missing analysis. According to the transcript, Judge Brownlee identified multiple technical violations. The appendix to the initial brief had not been bookmarked, failing to comply with Florida Rule of Appellate Procedure 9.220(C). The corrected appendix, ordered to be filed within 10 days, was submitted well after that deadline. Ramsaran did not file any motion requesting the late filing be accepted.

A second issue concerned documents included in the appendix that may not have been part of the record on appeal. According to the transcript, Judge Brownlee noted that the Texas case materials included in the appendix ran to 63 pages, while the third amended complaint in the record, including all attachments, was only 57 pages - making it mathematically impossible for all appendix materials to have been attached to that filing. Ramsaran acknowledged he could not confirm whether all items in the appendix were in the record on appeal.

There was also no transcript of the trial court hearing at which Judge Falcone had orally stated his reasons for dismissal. Ramsaran acknowledged that the order specifically referenced reasons stated on the record, and that he had no transcript of that hearing. According to the transcript, Judge White asked how, without a transcript, and without an argument section, and with an order carrying a presumption of correctness, the appeal could be considered a good faith filing.

Ramsaran's response was that he had not fully appreciated, at the time he reviewed the brief, that it could be construed as frivolous.

According to the transcript, the brief also contained the wrong signature block - listing "attorney for appellant Contractor Litigation Financing LLC," a party with no involvement in the case. Ramsaran attributed this to copy-pasting.

The statement of facts section was identified as presenting additional problems. According to the transcript, Judge Brownlee pointed out that the phrase "at all material times thereto" was applied to singular, date-specific events - such as the filing of an invoice - where the phrase is meaningless. A duty can persist "at all material times." The signing of a contract cannot.

Who wrote it

When asked whether he had proofread the brief before filing it, Ramsaran said he had. But later in the hearing, he disclosed that the brief had been prepared by an assistant - a former attorney he described as a retired lawyer - and that he had reviewed and filed it. According to the transcript, he stated: "I looked it over. I I I granted it what didn't follow the standard of our argument our argument standards, but I thought it made sense."

He also acknowledged that, for the underlying appellate rules and procedures, including whether the trial court was required to make written findings in its dismissal order, he lacked the supporting legal authority at the time of filing. When asked under what authority he had been operating when he assumed that requirement existed, his response was: "As I sit here before you, I don't know it."

Notification and procedural awareness

A third line of questioning concerned why the amended brief had been filed so far out of time following the court's show cause order of June 18, 2024. Ramsaran told the panel that court notifications had been going to his spam folder, because the Sixth District sent orders through a system called "case mail" rather than through the standard e-filing portal. He also acknowledged that the Sixth District was his first time practicing before that court.

According to the transcript, Judge Brownlee pointed out that this was also the first time Ramsaran's firm had appeared before the Sixth District, and noted that the difference between how trial courts and appellate courts transmit orders is a basic procedural matter. Ramsaran was unaware that appellate rules allowed counsel, in the absence of a transcript, to work with opposing counsel to reconstruct the record from the trial court hearing. According to the transcript, his response when informed of this option was: "No, I am now. Thank you."

The underlying dispute

The core commercial issue - the one that was supposed to be appealed - involved Foreman Electric Services and a contract dispute with a subcontractor named Howeron, which had sold its invoices to LSQ Funding Group under an invoice purchase agreement. Foreman contended it was a third-party beneficiary to that agreement, a legal theory that would have given it standing to pursue LSQ directly. Judge Falcone had dismissed the action with prejudice and denied leave to file a third amended complaint, finding any further amendment would be futile.

According to the transcript, Ramsaran argued in the hearing that LSQ's affirmative defenses in a separate action, combined with Paragraph 11 of the invoice purchase agreement, created a cognisable factual dispute about whether LSQ had represented that it would pay contractors including Foreman. The judges noted that the word in the contract was "authorized," not "obligated" - a distinction that went to the heart of whether any third-party beneficiary claim could survive. But the more fundamental point, as Judge White articulated in the transcript, was that none of this analysis appeared in the brief. The question of whether the argument had any merit was secondary to the fact that no argument had been made.

Why this matters beyond one courtroom

The hearing was conducted via Zoom and recorded. It appeared on the CourtCam Live channel on YouTube, timestamped May 31, 2026, and had accumulated 102 comments within days. The comment section was largely uniform in its reaction - viewers expressed disbelief at the combination of 10 years of practice, repeated appearance before appellate panels, and an apparent inability to construct a legal argument.

But the case cuts to a question that has been building across professional services: what does it mean to be competent when AI tools can produce credible-looking outputs that simulate competence without supplying it?

PPC Land has reported on research showing that hallucination rates in large language models correlate directly with how frequently facts appear in training data - if 20 percent of facts about a given domain appear only once in pretraining data, models hallucinate on at least 20 percent of queries in that domain. Legal procedure, particularly state appellate rules, is precisely the kind of domain where sparse, jurisdiction-specific facts create high hallucination risk.

A separate Florida case from April 2026 - Kings Roofing NWFL LLC v. Fusion Works Construction LLC - resulted in a Florida Sixth District order expressly retaining jurisdiction to pursue sanctions against counsel whose brief contained citations that appeared to be fabricated, with the court writing that the brief looked as if it had been drafted with the assistance of generative AI without sufficient safeguards.

The two cases, both in the same court, within months of each other, point toward a structural pattern rather than individual failure.

PPC Land has documented how Singapore's Infocomm Media Development Authority identified in a May 2026 discussion paper that existing legal frameworks were not designed for non-deterministic AI systems operating across long, multi-actor value chains - a problem directly relevant to situations where a professional delegates knowledge work to a system and then supervises the output inadequately.

The pattern extends into marketing and advertising. Research tracked by PPC Land from McKinsey found that only 39 percent of organisations attributed any measurable EBIT impact to AI use, despite widespread adoption - suggesting that the deployment of AI tools and the realisation of genuine capability from those tools remain substantially separate events. Skills shortages remain a documented constraint, with 43 percent of midmarket companies citing talent gaps as a barrier to scaling AI programs.

What the Ramsaran hearing illustrates, in unusually documented form, is what the failure mode looks like when the gap between deploying a tool and understanding the domain it operates in is never closed. The brief looked like an appellate brief. It had headers, citations, a statement of facts, a signature block. It lacked only one thing: legal argument. And the person who filed it, according to his own testimony, did not recognise that absence until three judges identified it, one question at a time.

According to the transcript, after the extended examination concluded, Ramsaran told the panel: "I'm starting to see the struggle you guys have had with this." The court stated it would issue a written order on sanctions. At the time of publication, no ruling had been made public.


Timeline

  • June 18, 2024 - Florida Sixth District Court of Appeal issues per curiam affirmance in Foreman Electric Services v. LSQ Funding Group (case 6D23-2601), Judges White, Mize, and Brownlee concurring
  • June 18, 2024 - Court issues show cause order regarding the brief; Ramsaran later states he misunderstood it as being about his failure to respond rather than the contents of the brief itself
  • April 10, 2026 - Florida Sixth District retains jurisdiction for sanctions in Rodriguez matter involving AI-generated citations, cited as precedent in the later Kings Roofing case
  • April 22, 2026 - Florida Sixth District dismisses Kings Roofing NWFL LLC v. Fusion Works Construction LLC but retains jurisdiction for sanctions against counsel whose brief contained citations that appeared to be fabricated, noting the brief appeared drafted with AI without adequate safeguards
  • May 2026 - Singapore's Infocomm Media Development Authority publishes 36-page discussion paper on legal liability for AI agents, assembled by a working group of over 20 legal professionals; covered by PPC Land
  • May 25, 2026 - Ramsaran files amended response to court (the "25th of this month" referenced in the transcript)
  • May 31, 2026 - Florida Sixth District holds special Zoom session on sanctions in Foreman Electric v. LSQ; hearing published same day on YouTube by CourtCam Live, accumulating 7,879 views and 102 comments within days
  • June 4, 2026 - Robert Freund, advertising and e-commerce attorney, shares hearing clip on LinkedIn; post receives five reactions and broad professional commentary; PPC Land's reporting on AI hallucinations and AI skills gapsprovides context for the professional competence debate the hearing has surfaced

Summary

Who: Jerome Ramsaran, a Miami attorney with 10 years of practice and a consumer protection focus, appeared before Florida Sixth District Court of Appeal Judges White, Brownlee, and Mize in a sanctions hearing. Opposing counsel Kevin Fowler of Foley and Lardner was present but took no active role.

What: A show cause hearing under Florida Rule of Appellate Procedure 9.410(A) and Section 57.105(1)(B) examined whether Ramsaran's amended initial brief in case 6D23-2601 was frivolous or in bad faith. The panel found the argument section contained only copied rules and case citations with no analysis. Ramsaran acknowledged the brief contained no argument, that a retired lawyer on his staff had drafted it, and that he lacked legal authority for central premises of the appeal at the time of filing.

When: The hearing took place on May 31, 2026, via Zoom, and was published the same day. The underlying affirmance dated to June 18, 2024. The proceeding had received 7,879 views and 102 YouTube comments within four days of publication.

Where: Florida Sixth District Court of Appeal, which handles appeals from Orange County among other jurisdictions. The court, established January 1, 2023, is headquartered in Lakeland, Florida.

Why: The hearing is significant beyond its immediate legal context because it captures, in documented and public form, what the gap between AI-assisted document production and genuine professional knowledge looks like in a high-stakes setting. As AI tools proliferate across professional services - law, marketing, medicine, finance - the Ramsaran hearing provides a case study in what happens when outputs are accepted without the underlying competence to evaluate them.