Rochon Eidsvig & Rochon Hafer v. JGB Collateral
Texas CA · Jun 12, 2025
- Jurisdiction
- state
- Court
- Texas CA
- Record ID
- rochon-eidsvig-rochon-hafer-v-jgb-collateral-2025-06-12
- Observed outcome
- The court ordered the attorney to complete eight hours of CLE (three ethics, five technology) and pay $2,500 in attorney's fees to the appellee.
- Known monetary consequence
- $2,500
Why this matter warrants attention
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.
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.
Eight hours of mandatory AI ethics CLE is the new baseline sanction — train your attorneys now or let a court do it publicly.
Failure modes and consequences
- Fake Citations
- Contract
- Trial
- None Adjudicated
- AI attribution
- Implied
- Recorded tool
- Generative A.I.
- Known monetary consequence
- $2,500
- Procedural posture
- 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.
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 references the ethical use of generative A.I.
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.
- 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.