In re: Marguerite Latete Kilpatrick
S.D. Ohio (Bankruptcy) · Nov 24, 2025
What happened in this matter?
The Court denied the debtor's emergency motion for stay and motion to withdraw the reference, finding them moot and frivolous. The Court explicitly flagged the debtor's use of AI to generate fabricated and misapplied legal citations as a basis for ongoing Rule 9011(c) sanction proceedings.
- Why the court cared
- Fabricated: Case Law | Debtor cited 'In re Miller, 150 B.R. 834 (Bankr. N.D. Ohio 1993)', which the Court found to be non-existent and noted 150 B.R. 834 corresponds to Brandt v. 440 Assocs., indicating a made-up citation; Court flagged this as a potential AI hallucination and basis for Rule 9011 review. || Misrepresented: Case Law | Debtor relied on In re Pan Am Corp., 159 B.R. 396, 400 (S.D.N.Y. 1993) for the proposition that status quo should be maintained pending withdrawal; Court found that Pan Am addressed Rule 54(b) and dismissal of appeals, not withdrawal/stay, so the authority was misapplied.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in S.D. Ohio (Bankruptcy), with the listed outcome: no adjudicated outcome recorded.
Why this matter is tracked
The Bankruptcy Court for the S.D. Ohio addressed an emergency motion for stay filed by a pro se debtor, Marguerite Latete Kilpatrick, following the dismissal of her third bankruptcy case within a year. The Court identified that the debtor's filings, likely generated with the assistance of AI, contained fabricated and misapplied case law, including a non-existent citation to 'In re Miller, 150 B.R. 834'. The Court noted these filings were part of a pattern of sovereign citizen-based litigation intended to delay foreclosure proceedings. Consequently, the Court denied the debtor's motions as moot and frivolous, while reserving jurisdiction to conduct a hearing regarding potential sanctions under Bankruptcy Rule 9011(c) for the submission of baseless and AI-generated content.
This record documents a Pro Se Litigant filing issue in S.D. Ohio (Bankruptcy), with the listed outcome: no adjudicated outcome recorded.
Record details
What the record establishes about AI use
The Court identified ChatGPT as a likely tool used by the debtor.
Order denying emergency motion for stay and motion to withdraw the reference, with ongoing jurisdiction reserved for Rule 9011(c) sanction proceedings.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Debtor cited 'In re Miller, 150 B.R. 834 (Bankr. N.D. Ohio 1993)', which the Court found to be non-existent and noted 150 B.R. 834 corresponds to Brandt v. 440 Assocs., indicating a made-up citation; Court flagged this as a potential AI hallucination and basis for Rule 9011 review.
- Misrepresented: Case Law | Debtor relied on In re Pan Am Corp., 159 B.R. 396, 400 (S.D.N.Y. 1993) for the proposition that status quo should be maintained pending withdrawal; Court found that Pan Am addressed Rule 54(b) and dismissal of appeals, not withdrawal/stay, so the authority was misapplied.
Questions this record answers
- What happened in In re: Marguerite Latete Kilpatrick?
- The Court denied the debtor's emergency motion for stay and motion to withdraw the reference, finding them moot and frivolous. The Court explicitly flagged the debtor's use of AI to generate fabricated and misapplied legal citations as a basis for ongoing Rule 9011(c) sanction proceedings.
- Why does In re: Marguerite Latete Kilpatrick matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in S.D. Ohio (Bankruptcy), with the listed outcome: no adjudicated outcome recorded.
- What does the public record establish about In re: Marguerite Latete Kilpatrick?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this In re: Marguerite Latete Kilpatrick summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.