In re Richburg
D. South Carolina (Bankruptcy) · Aug 27, 2025
- Jurisdiction
- federal
- Court
- D. South Carolina (Bankruptcy)
- Record ID
- in-re-richburg-2025-08-27
- Observed outcome
- Counsel was ordered to complete three hours of CLE on ethics and the use of AI in legal practice, in addition to standard bar requirements.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court sanctioned counsel for a Rule 9011 violation after he submitted AI-generated, nonexistent case citations in a motion. The court ordered counsel to complete three hours of CLE on ethics and AI, declining to impose monetary sanctions due to procedural constraints following the voluntary dismissal of the underlying motion.
The court reasoned that counsel failed to meet the duty of objective reasonableness under Rule 9011 by relying on AI-generated content without verifying the existence or accuracy of the cited authorities. The court determined that while the conduct was sanctionable, monetary sanctions were barred because the show cause order was issued after the voluntary dismissal of the motion.
Microsoft CoPilot is not a legal research tool; mandate an approved-tools list and require independent verification before any filing.
Failure modes and consequences
- Fake Citations
- Trial
- Professional
- AI attribution
- Admitted
- Recorded tool
- Microsoft CoPilot
- Known monetary consequence
- Not recorded
- Procedural posture
- The court issued a show cause order sua sponte regarding potential Rule 9011 violations after discovering fabricated citations in a motion for preliminary injunction. Following a hearing, the court issued an order imposing nonmonetary sanctions.
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
Counsel admitted using Microsoft CoPilot to generate citations.
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.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to Microsoft CoPilot output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.