McDowell et al. v. Turpen
D. Colorado (Bankruptcy) · Feb 17, 2026
- Jurisdiction
- federal
- Court
- D. Colorado (Bankruptcy)
- Record ID
- mcdowell-et-al-v-turpen-2026-02-17
- Observed outcome
- The court denied the motion to dismiss in part and granted it in part, while issuing a formal warning to the defendant regarding AI usage and Rule 9011 compliance.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to a pro se defendant for including AI-generated prompts and a fabricated case citation in a motion to dismiss. The court emphasized that pro se parties are subject to Fed. R. Bankr. P. 9011 and that failure to verify the existence and accuracy of legal citations may result in sanctions.
Fabricated: Case Law | Pro se defendant cited a non-existent case 'In re Raspanti, 414 B.R. 263 (Bankr. D. Colo. 2009)'; the Court identified the citation as fake and warned about AI-generated content and Rule 9011 compliance.
This record documents a Pro Se Litigant filing issue in D. Colorado (Bankruptcy), with the listed outcome: no adjudicated outcome recorded.
Failure modes and consequences
- Hallucinated_case_law
- Inadequate_verification_of_ai_output
- Pro Se
- Fake Citations
- Contract
- Trial
- AI attribution
- Explicitly Recorded
- Recorded tool
- unspecified generative AI
- Known monetary consequence
- Not recorded
- Procedural posture
- Order granting in part and denying in part a motion to dismiss in a bankruptcy adversary proceeding.
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 identified the presence of AI prompts in the motion.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.