In re Richburg
The case
In re Richburg, United States Bankruptcy Court for the District of South Carolina, August 27, 2025. Copy of primary document: ~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-81-in-re-richburg.pdf
What happened
Attorney Paul L. Held used Microsoft CoPilot, a generative AI platform, to draft a filing and included citations to two nonexistent cases without verifying them before filing on CM/ECF. He relied on short blurbs CoPilot supplied summarizing the cases rather than reading the authorities.
The rule and the sanction
The court found a violation of Federal Rule of Bankruptcy Procedure 9011 and imposed a non-monetary sanction: three additional hours of continuing legal education on ethics, including at least two hours on the ethical use of artificial intelligence in legal practice, in addition to any South Carolina Bar requirements, with a certification of compliance due by February 1, 2026.
How it could have been avoided
Read the full text of every AI-surfaced case before citing it; summaries and blurbs are not substitutes. Build a pre-filing checklist that requires opening each cited authority in a legal database.