In re Rosslyn2016, LLC, et al.
S.D. Texas (Bankruptcy) · Jul 14, 2026
- Jurisdiction
- federal
- Court
- S.D. Texas (Bankruptcy)
- Record ID
- in-re-rosslyn2016-llc-et-al-2026-07-14
- Observed outcome
- The court ordered the attorney to complete six hours of CLE on generative AI and to pay $29,877 in attorney's fees to the bankruptcy estate.
- Known monetary consequence
- $29,877
Why this matter warrants attention
The court sanctioned attorney Gregory W. Mitchell for submitting filings containing fabricated case law and non-existent citations generated by AI or unverified templates. The court ordered Mitchell to complete six hours of CLE on generative AI and to pay $29,877 in attorney's fees to the bankruptcy estate for bad-faith conduct.
The court reasoned that Rule 11(b) imposes an objective standard of reasonableness that cannot be satisfied by good faith alone. It held that Mitchell's failure to verify citations—whether generated by AI or copied from templates—constituted a violation of Rule 11(b). Furthermore, the court invoked its inherent power and 11 U.S.C. § 105(a) to award attorney's fees, finding that Mitchell acted in bad faith by using unverified, fabricated authority as part of a broader scheme to abuse the bankruptcy process.
This case illustrates the severe consequences of failing to verify AI-generated or template-based legal research. It confirms that courts will use inherent powers to sanction bad-faith conduct even when procedural rules like Rule 11 have specific limitations on fee awards.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Published Opinion
- Bankruptcy
- Trial
- AI attribution
- Admitted
- Recorded tool
- Westlaw Precision
- Known monetary consequence
- $29,877
- Procedural posture
- The court issued a sua sponte show cause order under Rule 11(c)(3) following the submission of frivolous motions to quash, subsequently imposing sanctions under its inherent authority and 11 U.S.C. § 105(a).
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
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What this record does—and does not—establish
Attorney used Westlaw Precision.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.