In re Marla C. Martin
U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division · Bankr. N.D. Ill. · Illinois bar guidance
Verified April 26, 2026
- Citation
- In re Martin, No. 24-bk-13368 (Bankr. N.D. Ill. July 18, 2025) (Slade, J.)
- Decided
- July 18, 2025
Summary
Debtor's counsel Thomas E. Nield of the Semrad Law Firm filed a brief containing fabricated case citations and false quotations generated by ChatGPT without verification. The brief cited In re Montoya, 341 B.R. 41 (Bankr. D. Utah 2006), a real case, but attributed quoted language that does not appear in the opinion. Bankruptcy Judge Michael B. Slade found the conduct violated Federal Rule of Bankruptcy Procedure 9011(b).
- AI tool:
- ChatGPT
- Sanction amount:
- $5,500
What sanction did the court impose?
Joint and several sanction of $5,500 payable to the Clerk of the Bankruptcy Court against Nield and a senior attorney at the Semrad Law Firm, plus mandatory attendance at an AI-focused educational session at the National Conference of Bankruptcy Judges annual meeting. The firm separately withdrew its fee request, adopted an internal AI policy, and required firm-wide CLE on ethical AI use.
Why does In re Marla C. Martin matter for law firms using AI?
In re Martin is notable because the hallucination was subtler than the canonical Mata v. Avianca pattern: the cited case was real, but the AI fabricated quoted language attributed to it. Verifying that a case exists is not enough; the underlying text must be checked against the actual opinion. Judge Slade’s opinion is widely quoted for the line that “any lawyer unaware that using generative AI platforms to do legal research is playing with fire is living in a cloud,” and the firm’s response, an internal AI policy plus mandatory CLE, is a useful template for managing partners drafting their own governance documents.