In re Troylond Malon Wise
Repeat offender (verified in the record) Episode 11
The case
The sequel, in a different court. Kathleen Wilson's Withers filings were not her only ones. Weeks after the Withers show-cause hearing, she filed bankruptcy pleadings in the Western District of Louisiana carrying the same species of AI hallucinations, including a citation to a Louisiana statute that does not exist. She did not tell this court about the Mississippi proceedings. The bankruptcy court learned about them from the record, and its order is the tracker's clearest statement of how a repeat sequence compounds.
What happened
Wilson admitted using generative AI to create her Objection to a Motion for Relief from Stay and a Supplemental Response in In re Troylond Malon Wise. The filings cited an incomplete and unsupported In re Garcia, an In re Buttermilk Towne that resolves to no opinion, and La. R.S. 9:5774, a statute that does not exist. She filed both pleadings without reviewing or verifying the AI output.
The rule and the sanction
Federal Rule of Bankruptcy Procedure 9011(b)(2). Wilson was ordered to pay a $2,750 monetary sanction to the clerk within 10 days. She is barred from filing any new bankruptcy case, or participating in any other, in the Western District of Louisiana until she submits proof of six hours of in-person CLE on AI use in practice, including an hour each of ethics and professionalism. The objection and both responses were struck as if never filed.
How it could have been avoided
Verify every AI-generated citation, statute numbers included, before filing; a fake statute is as easy to check as a fake case. When you are already answering for this conduct in one court, disclosure to the second court is not optional. Admission still helped her here, but it could not outrun the sequence.
Watch the episode
This case is covered in Episode 11: Every Lawyer in the Case Got Sanctioned (Ep 11) (watch on YouTube).