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In re Garcia-Martz

United States Bankruptcy Court for the Northern District of Indiana · Federal bankruptcy courts · IN · · 2026 WL 1815400 · No. 25-31324 · order

On 2026-06-10, in In re Garcia-Martz, the Northern District of Indiana Bankruptcy Court ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.

Disposition
The court ordered the filer to show cause why sanctions should not issue for the defective authorities.
Recorded conduct
Counsel filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions they did not support, and a nonexistent rule or legal standard. — outcome: pending; actor: lawyer
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Figure 3 below cites the 13 deficient arguments previously mentioned above; captures additional questionable arguments, misleading quotes, a non-existent Bankruptcy Rule; internally inconsistent and contradictory arguments; and describes other problems with the Trustee's Brief. The Court would not have a problem if the issues below were isolated, or if only a few of them appeared. But collectively, they may suggest that the Trustee has violated one or more of the Ind. R. Prof. Cond or Fed. R. Bank. P 9011. Figure 316 : Deficiencies in the Trustee's Brief VI. Conclusion *12 The Court rejects the Trustee's arguments. First, the majority approach to the §§ 1326(a)(2) – 349(b)(3) divide is thebetterapproach.ButeveniftheCourtappliedtheminority approach,theresultwouldbethesame.GeraciLawisentitled to the administrative expense it seeks, and the Trustee must disburse the funds to Debtor's attorneys. To the Trustee's second argument, the Trustee is wrong about “binding” case law. ... The second order will direct the Trustee to show cause in writing and at a hearing, why she should not be sanctioned for the 13 issues highlighted in Figure 3. SO ORDERED. In re Garcia-Martz, --- B.R. ---- (2026) All Citations --- B.R. ----, 2026 WL 1815400 Footnotes 1 Aside from Section I of this Decision, when the Court discusses jurisdiction and venue, all future references to statutes will be to Title 11, the Bankruptcy Code. The Code does not capitalize “Title” or “Chapter.” See, e.g., § 503. Many courts capitalize Title and Chapter. See, e.g., Marshall v. Johnson, 100 F.4th 914, 918 (7th Cir. 2024).

Authorities cited in the passage: Marshall v. Johnson, 100 F

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