Kheir v. Titan Team LLC
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.