In re Marla C. Martin
The case
In re Marla C. Martin, United States Bankruptcy Court for the Northern District of Illinois, July 18, 2025, No. 24 B 13368 (sanctions opinion). Copy of primary document: ~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-72-in-re-marla-c-martin.pdf
What happened
Attorney Thomas E. Nield of The Semrad Law Firm, LLC filed a brief containing fake quotations and nonexistent authority manufactured by artificial intelligence. Nield used ChatGPT to prepare the brief without verifying the authorities, and the court found the brief contained fabricated quotations and authorities that did not exist as represented. Semrad withdrew the offending brief after the court issued its show-cause order. Nield self-reported his behavior to the IARDC, and Semrad withdrew its request for compensation in this case, adopted a formal Artificial Intelligence Policy, required all firm attorneys to complete online CLE training in the ethical and appropriate use of AI in legal practice, and offered to reimburse opposing counsel for time spent reviewing the offending brief, response conduct the court expressly credited in its "candor and remorse" assessment when fixing the sanction (ORDER p. 17).
The rule and the sanction
The court found a violation of Federal Rule of Bankruptcy Procedure 9011. It imposed a joint-and-several penalty of $5,500 on Nield and Semrad, payable to the Clerk of the Bankruptcy Court, and required Nield and another senior Semrad attorney to attend an in-person course on the dangers of AI at the National Conference of Bankruptcy Judges annual meeting. Source: https://www.ilnb.uscourts.gov/sites/ilnb/files/opinions/179623_MartinRule9011SanctionsOpinionwTransmittalSheet%201.pdf
How it could have been avoided
Read every cited authority in full before filing rather than trusting AI-generated quotations. Have a second attorney independently verify all citations in any AI-assisted filing.