In re: Todd Elliott Koger
W.D. Pennsylvania (Bankruptcy) · Sep 30, 2025
- Jurisdiction
- federal
- Court
- W.D. Pennsylvania (Bankruptcy)
- Record ID
- in-re-todd-elliott-koger-2025-09-30
- Observed outcome
- The court dismissed the adversary proceeding with prejudice, denied the motion to reopen the prior bankruptcy case, and imposed a one-year filing bar.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court imposed a one-year filing bar on the pro se litigants after determining their filings were abusive and contained fabricated legal citations, which the court suggested may have been generated by AI.
The court reasoned that the litigants' arguments were barred by claim and issue preclusion following final state court judgments, and that the inclusion of fabricated citations in their filings constituted an abuse of the bankruptcy system warranting a filing bar.
This case illustrates the judicial response to pro se litigants using AI-generated or fabricated legal citations to relitigate settled matters, resulting in a formal filing bar to prevent further abuse of court resources.
Failure modes and consequences
- Pro Se
- Fake Citations
- Bankruptcy
- Trial
- Bar Referral
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court issued a Memorandum Opinion dismissing an adversary proceeding with prejudice and denying a motion to reopen a prior Chapter 7 bankruptcy case.
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 noted the citations appeared fabricated and suggested the use of AI.
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 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.