In re Rosslyn2016, LLC, et al.
S.D. Texas (Bankruptcy)
- Judge
- —
- Date filed
- —
- Sanctioned
- 2026-07-14
- AI tool
- Westlaw Precision
- Monetary penalty
- 29877 USD
- Outcome
- CLE on generative AI; Civil Contempt; Adverse Costs Order
What happened
In re Rosslyn2016, LLC, et al. was decided 2026-07-14 in S.D. Texas (Bankruptcy). The court found that filings in this matter contained AI-generated citations that could not be verified against any primary source.
Court outcome: CLE on generative AI; Civil Contempt; Adverse Costs Order.
The fabricated citations
Misrepresented: Case Law
Attorney cited 'In re Grand Jury Subpoena, 870 F.2d 343' for attorney-client privilege; court found the citation incorrect/misused—the reported case is Grubbs v. Norris, 870 F.2d 343 (6th Cir.), which does not support the asserted privilege proposition.
Fabricated: Case Law
Motion quoted 'premature and unauthorized substitute for formal discovery' attributed to In re Dinnubilo; court found the direct quotation does not exist in Dinnubilo or other published opinions.
Misrepresented: Case Law
Motion claimed Table Talk supports limiting Rule 2004 due to 'disproportionate burdens on non-debtor third parties'; court found this was a misrepresentation and that Table Talk rejects the argument.
Fabricated: Case Law
Motion attributed the statement that Rule 2004 is inappropriate 'when a specific dispute has matured...' to In re Symington; court found the quotation does not appear in Symington.
Fabricated: Case Law
Motion quoted that Rule 2004 'may not be used as a device for discovery in anticipated litigation' and cited Wilcher and Bennett Funding Group; court found the phrasing/quotation does not exist in those opinions and was misleading.
How Citation Safe would have caught this
Citation Safe would have flagged the fabricated and misrepresented citations documented in this opinion by cross-checking each cite string against CourtListener's primary-source database of federal and state opinions, and by comparing every quoted passage against the actual text of the cited source. The pattern above (mix of non-existent cites and real cites paired with fabricated quotations) is the exact failure mode the tool is built to catch.
Sources
Run Opposition Check on any brief you’re about to file for — $49.
Full annotated report on every citation in the opposing filing. Attach it to your Rule 11 or sanctions motion.