In re Rosslyn2016, LLC, et al.
The case
In re Rosslyn2016, LLC, et al., Bankr. S.D. Tex., Case No. 25-34507, Document 312, filed July 14, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-159-in-re-rosslyn2016.pdf`.
What happened
Counsel for the petitioning creditors (Mitchell) submitted four motions to quash (ECF Nos. 218 through 221) containing fabricated quotations, nonexistent citations, and invented legal authority. The trustee identified them as apparent AI hallucinations that exist in no cited case or any other case law. At the June 10, 2026 hearing, Mitchell testified that the citations came from a prior template whose origin he could not recall, denied using ChatGPT, but acknowledged using AI tools available through Westlaw in his practice.
The rule and the sanction
Federal Rule of Civil Procedure 11(b) (via the Southern District of Texas General Order 2025-04, which holds attorneys responsible for the contents of filings regardless of whether generative AI drafted any portion). As a sanction for the Rule 11(b) violation, Mitchell must register for and complete six hours of Texas continuing legal education on the use of generative AI in the courts and file a certificate of compliance by August 31, 2026. Note: the court also held Mitchell and the petitioning creditors in civil contempt and made them jointly liable for $29,877 in the trustee's fees and costs, but that award covered the broader bad-faith scheme and noncompliance with court orders, not solely the AI misuse.
How it could have been avoided
AI tools built into legal research platforms hallucinate like any other AI; "came from a prior template" is not verification. Pull and read each cited case before filing, and treat the S.D. Tex. General Order 2025-04 warning as a personal duty rather than a suggestion.
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