In re Lisa Cato
D. D.C. (Bankruptcy) · Jul 10, 2026
- Jurisdiction
- federal
- Court
- D. D.C. (Bankruptcy)
- Record ID
- in-re-lisa-cato-2026-07-10
- Observed outcome
- Motion for Sanctions denied.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court denied the motion for sanctions because the movant failed to comply with the mandatory safe harbor notice requirements of Bankruptcy Rule 9011(c). Additionally, the court determined the movant's substantive arguments regarding the validity of a certificate of service and the admissibility of pleading allegations were legally meritless.
The court reasoned that the motion was procedurally barred by the failure to provide the mandatory 21-day safe harbor notice required by Bankruptcy Rule 9011(c). On the merits, the court found the movant's arguments regarding the validity of a paralegal's signature on a certificate of service and the application of the Rules of Evidence to pleading allegations were legally flawed and unsupported by the cited authorities.
This case illustrates judicial scrutiny of pro se filings involving hallucinated caselaw and the enforcement of procedural prerequisites like the Rule 9011 safe harbor. It highlights the court's reliance on prior orders requiring AI-use certification to manage recurring citation inaccuracies.
Failure modes and consequences
- Fabricated Legal Citations
- Fabricated Quotations
- Misstatements Of Law
- Failure To Comply With Procedural Rules
- Pro Se
- Fake Citations
- AI attribution
- Implied
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order denying Motion for Sanctions following a hearing held on March 25, 2026.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court referenced a prior order requiring certification of generative AI use.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.