In re Kathleen A. Rabon
U.S. Bankruptcy Court, District of Connecticut · Bankr. D. Conn. · Connecticut bar guidance
Verified May 14, 2026
- Citation
- In re Kathleen A. Rabon, No. 25-21127 (JJT) (Bankr. D. Conn. Apr. 3, 2026)
- Decided
- April 3, 2026
Summary
The bankruptcy court issued an order to show cause against debtor's counsel after a filing included a fabricated quotation attributed to a real case. The court identified the false quote as the kind of error characteristic of unverified generative AI output, although the order does not name the specific tool used.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause why sanctions should not be imposed. No monetary penalty was entered as of the date of the order; the show-cause proceeding was set to determine whether sanctions, including discipline, would follow.
Why does In re Kathleen A. Rabon matter for law firms using AI?
Rabon illustrates that bankruptcy courts, like district courts, are now treating fabricated quotations as a self-executing trigger for show-cause process. For a small firm with a consumer bankruptcy practice, the takeaway is that a single unverified quote pulled from an AI draft is enough to put the signing attorney in front of the judge to explain themselves, even where no opposing counsel has flagged the error.
Sources
Further reading
- https://www.damiencharlotin.com/documents/1955/R_Rabon_USA_3_April_2026.pdf
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- The presiding judge is identified in the order only by the initials "JJT"; the judge's full name is not spelled out in the order text.