Rochon Eidsvig & Rochon Hafer v. JGB Collateral
Texas CA · Jun 12, 2025
What happened in this matter?
The court sanctioned attorney Heidi R. Hafer for filing a brief with four fabricated case citations. The court ordered the attorney to complete eight hours of CLE (three in ethics, five in technology) and to pay $2,500 in attorney's fees to the appellee's counsel.
- Why the court cared
- The court reasoned that under the Texas Disciplinary Rules of Professional Conduct, attorneys must maintain competence regarding the risks of technology and ensure the accuracy of all filings. The panel determined that relying on technology without verification violates the duties of competence and candor, justifying a sanction to educate the attorney and uphold professional standards.
- Why it matters now
- Eight hours of mandatory AI ethics CLE is the new baseline sanction — train your attorneys now or let a court do it publicly.
Why this matter is tracked
Fabricated: Case Law | First of four non-existent case citations in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief. Outcome: 8 mandatory hours of Continuous Legal Education on ethics and AI. "Regardless of whatever resources are used to prepare a party’s brief, every attorney has an ongoing responsibility to review and ensure the accuracy of filings with this and other courts. This includes checking that all case law cited in a brief actually exists and supports the points being made. It is never acceptable to rely on software or technology—no matter how advanced—without reviewing and verifying the information. The use of AI or other technology does not excuse carelessness or failure to follow professional standards.Technology can be helpful, but it cannot replace a lawyer’s judgment, research, or ethical responsibilities. The practice of law changes with the use of new technology, but the core duties of competence and candor remain the same. Lawyers must adapt to new tools without lowering their standards."
Eight hours of mandatory AI ethics CLE is the new baseline sanction — train your attorneys now or let a court do it publicly.
Record details
What the record establishes about AI use
The court references the ethical use of generative A.I.
The court issued an order on June 12, 2025, following a May 8, 2025 hearing regarding the inclusion of non-existent case law in an opening brief filed on May 16, 2024.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | First of four non-existent case citations in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief.
- Fabricated: Case Law | Second non-existent case citation in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief.
- Fabricated: Case Law | Third non-existent case citation in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief.
- Fabricated: Case Law | Fourth non-existent case citation in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief.
Questions this record answers
- What happened in Rochon Eidsvig & Rochon Hafer v. JGB Collateral?
- The court sanctioned attorney Heidi R. Hafer for filing a brief with four fabricated case citations. The court ordered the attorney to complete eight hours of CLE (three in ethics, five in technology) and to pay $2,500 in attorney's fees to the appellee's counsel.
- Why does Rochon Eidsvig & Rochon Hafer v. JGB Collateral matter for legal AI risk?
- Eight hours of mandatory AI ethics CLE is the new baseline sanction — train your attorneys now or let a court do it publicly.
- What does the public record establish about Rochon Eidsvig & Rochon Hafer v. JGB Collateral?
- 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.
- Which source supports this Rochon Eidsvig & Rochon Hafer v. JGB Collateral 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.
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