In re Latasha Transrina Kebe
U.S. Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division · Bankr. S.D. Fla. · Florida bar guidance
Conduct
Debtor's counsel filed a response with citation errors that opposing counsel caught; counsel acknowledged them in a corrective notice and apologized.
Consequence
Bankruptcy Rule 9011 sanction on counsel and his firm: 10% of the creditor's reply-brief fees, fixed at $2,231.84 and payable to the creditor.
Lesson
Here an apology and a corrective notice did not end the matter; the court tied a Rule 9011 sanction to the opponent's cost of the reply that exposed the errors.
Verified September 29, 2026
- Citation
- In re Latasha Transrina Kebe, No. 23-14082-SMG, Order (I) Granting in Part and Denying in Part, Without Prejudice, Belcalis Marlenis Almánzar's Motion to (I) Enforce Confirmed Plan and Confirmation Order and (II) Impose Sanctions, Including Attorneys' Fees and Costs, and (II) Imposing Rule 9011 Sanctions Against Debtor's Counsel (Bankr. S.D. Fla. May 13, 2026) (Grossman, C.J.), ECF No. 225
- Decided
- May 13, 2026
Summary
In the Subchapter V Chapter 11 case of Latasha Transrina Kebe, creditor Belcalis Marlenis Almánzar moved to enforce the confirmed plan's non-disparagement clause and for sanctions. The debtor's response in opposition contained citation errors that Almánzar's reply identified; the debtor then filed a "Notice to Correct and Clarify Citations" acknowledging them. After a May 6, 2026 hearing, Chief Judge Scott M. Grossman entered the Sanctions Order on May 13, 2026. Most of it concerns the debtor: the court found her in civil contempt of the confirmation order for multiple violations of the non-disparagement clause across several social media platforms and a radio program, ordered her to cease and remove the content, and awarded the creditor her fees and costs. On the citations, the court accepted the apology tendered by debtor's counsel but found that "an apology, while appropriate, does not fully resolve Debtor's counsel's obligations under Bankruptcy Rule 9011." It noted that the deficiencies "were not discovered by Debtor's counsel prior to filing; they were identified by opposing counsel and documented in the Reply," and that counsel waived further hearing on the Rule 9011 issue.
- AI tool:
- Unidentified (the orders address citation errors that debtor's counsel acknowledged, but do not attribute them to AI or name a tool)
- Sanction amount:
- Bankruptcy Rule 9011 sanction against Chad T. Van Horn, Esq. and Van Horn Law Group, P.A., jointly and severally, equal to 10% of the creditor's fees for the reply brief; fixed at $2,231.84 by the June 30, 2026 agreed order, payable to the creditor
What sanction did the court impose?
Applying Bankruptcy Rule 9011(b)(2)'s objective standard (legal contentions must be warranted by existing law at the time of filing), the court found that the citation errors identified in the reply failed to meet it. It imposed a sanction under Bankruptcy Rule 9011 against Chad T. Van Horn, Esq. and Van Horn Law Group, P.A. equal to 10% of the fees and costs awarded to the creditor for researching and drafting the reply, payable directly to the creditor within twenty-eight days after the amount was fixed. A June 30, 2026 stipulation and agreed order fixed the reply award at $22,318.42 and the Rule 9011 sanction, jointly and severally, at $2,231.84, and provided that the sanction "is not compromised" by the separate settlement of the fee award between the debtor and the creditor. The broader fee award of $110,115.76 was compromised at $60,000, backed by guaranties from several non-debtor parties. Neither order mentions artificial intelligence.
Why does In re Latasha Transrina Kebe matter for law firms using AI?
In re Kebe is mainly a contempt ruling against a debtor, with a Rule 9011 holding attached. The citation errors surfaced in the creditor’s reply brief, and debtor’s counsel responded with a notice correcting and clarifying the citations and an apology. Chief Judge Grossman accepted the apology but held that it “does not fully resolve Debtor’s counsel’s obligations under Bankruptcy Rule 9011,” because the standard is objective and measured at the time of filing.
Rather than a fixed fine, the court set the sanction at 10% of the creditor’s fees for researching and drafting the reply, and made it payable to the creditor. When the parties later compromised the much larger fee award against the debtor, the agreed order expressly carved the Rule 9011 sanction out of the compromise and fixed it at $2,231.84.
Neither order describes the specific citation errors or mentions artificial intelligence; the AI coding on this entry comes from the tracker. Firms documenting compliance may wish to consider that, in this case, counsel’s waiver of a further hearing and corrective notice did not avoid a sanction once the court found the filing fell short of Rule 9011(b)(2) when made.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Verify citations before filing rather than after an opponent's reply. The court stressed that the errors "were not discovered by Debtor's counsel prior to filing."
- Document the firm's exposure: the sanction ran jointly and severally against the individual lawyer and the law firm.
- Consider how a fee-based sanction is measured. Here the court set it as a percentage of the opposing party's fees for the reply that identified the errors.
Sources
Primary sources
- AI attribution is a Charlotin tracker inference (coded 'implied'). Neither the May 13, 2026 Sanctions Order nor the June 30, 2026 agreed order mentions artificial intelligence or describes the specific citation errors; those are in the creditor's reply (Dkt. No. 222) and the debtor's corrective notice (Dkt. No. 223), which were not reviewed.