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In re Rosslyn2016, LLC, et al.

Court
S.D. Texas (Bankruptcy)
Jurisdiction
USA
Decided
2026-07-14
AI tool
Westlaw Precision
Outcome
CLE on generative AI; Civil Contempt; Adverse Costs Order
Monetary penalty
29877 USD

What was hallucinated

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.

Sanction teardown · S.D. Texas (Bankruptcy), USA · 2026-07-14

In re Rosslyn2016, LLC, et al.

What happened

In S.D. Texas (Bankruptcy), USA, a filing relied on Westlaw Precision to help draft legal argument. The court identified the following problems with the citations in that filing:

  • 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.

Which AI tool

Westlaw Precision. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

CLE on generative AI; Civil Contempt; Adverse Costs Order (monetary penalty: 29877 USD.)

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/2628/In_re_Rosslyn_USA_14_Jly_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2628/In_re_Rosslyn_USA_14_Jly_2026.pdf

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