Case D-105 · AI Sanctions Case Tracker

Kheir v. Titan Team LLC

U.S. Bankruptcy Court for the Southern District of Texas, November 4, 2025

Response class R4, Dodged It

The case

Kheir v. Titan Team LLC, main case No. 24-35814, adversary proceeding No. 25-3033 (Bankr. S.D. Tex.), sanctions opinion signed and entered November 4, 2025. (The master-list metadata dates this November 6 and lists a $1 penalty; both are errors. Trust the document.) Federal bankruptcy court. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-105-kheir-v-titan-team.pdf`.

What happened

Attorney Derrick D. King filed pleadings containing 32 AI-derived authorities that were nonexistent or materially misrepresented, supplied by his client and filed without verification. The filings violated the Southern District of Texas General Order 2025-04 on generative AI use and Bankruptcy Rule 9011.

The rule and the sanction

Bankruptcy Rule 9011 and General Order 2025-04. Sanctions: payment of Auction.com's reasonable fees and costs; six hours of Texas CLE on generative AI; service of the order on the client; a compliance certification by December 31, 2025; and referrals to the chief district judge and to State Bar of Texas disciplinary counsel.

How the lawyer responded

R4, Dodged It (opposing counsel's reply flagged the AI use; at the hearing counsel answered the AI-use questions with "Not on my behalf" and "I don't know"; counsel attributed the cases to client-supplied work and to not having Westlaw; no remediation is recorded before the ruling; the order imposes fees, CLE, client notice and referral with no stated credit for the response).

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How it could have been avoided

(a) Know your court's standing AI orders before filing; ignorance of a general order is not a defense. (b) Client-supplied authority must be verified independently, especially at volume: 32 unchecked authorities signals a complete absence of inquiry. (c) File the required AI-use certifications your court demands up front.