Courts on AI / Fabricated or misquoted citations
In re Troylond Malon Wise
U.S. Bankruptcy Court for the Western District of Louisiana · Federal bankruptcy courts · LA · · No. 25-51132 · order
On 2026-04-09, U.S. Bankruptcy Court for the Western District of Louisiana struck counsel’s objection and supplemental response, imposed a $2,750 sanction, ordered AI-focused CLE, and barred further filings until compliance. Counsel submitted a filing with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities, including In re Garcia and In re Buttermilk Towne LLC.
- Disposition
- The court struck counsel’s objection and supplemental response, imposed a $2,750 sanction, ordered AI-focused CLE, and barred further filings until compliance.
- Recorded conduct
- The filing used nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities, including In re Garcia and In re Buttermilk Towne LLC, which the court found nonexistent, misquoted, or unsupported. — outcome: sanctions; actor: lawyer; $2,750
- 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.
the underlying promissory note.” 2 Regardless of what Ms. Wilson may have intended by citing to In re Garcia, the Court finds that her failure to review and verify the AI-generated Objection caused her to file a false and misleading pleading in this Court. Ms. Wilson also acknowledges that her Supplemental Response (ECF # 67) contains an AI-generated case citation to In re Buttermilk Towne LLC which does not resolve to any opinion. In her Response to the Court’s Show Cause Order, she supplies what she claims is the correct citation but notes that even the correctly cited case “is not applicable to the legal argument which is correctly noted in Veal.” 3 Similarly, she admits that her Supplemental Response cites to La. R.S. § 9:5774, a statute that does not exist, and she claims that she should have cited to La. Civ. Code art. 3357, et seq., concerning the reinscription of mortgages. 4 Notwithstanding Ms. Wilson’s explanations, her failure to review and verify the admittedly AI-generated See Response, p. 1 (ECF #79). Id., p. 2. Id. Id. 25-51132 - #84 File 04/09/26 Enter 04/09/26 14:12:22 Main Document Pg 2
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