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Courts on AI / Fabricated or misquoted citations

In re Wise

United States Bankruptcy Court for the Western District of Louisiana · Federal bankruptcy courts · LA · · No. Case 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
Attorney Kathleen Wilson was ordered to pay $2,750 to the clerk, barred from bankruptcy practice in the district until she completed six hours of in-person AI CLE and paid the sanction, and her objection and responses were struck.
Recorded conduct
Wilson admitted using generative AI to create an objection and supplemental response; the objection cited In re Garcia for an unsupported proposition, the supplemental response cited nonexistent In re Buttermilk Towne LLC and nonexistent La. R.S. § 9:5774, and both pleadings were false and misleading. — outcome: fine; 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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