In re Troylond Malon Wise
U.S. Bankruptcy Court, Western District of Louisiana, Lafayette Division · Bankr. W.D. La. · Louisiana bar guidance
Verified April 26, 2026
- Citation
- In re Wise, No. 25-51132 (Bankr. W.D. La. Apr. 9, 2026) (ECF No. 84)
- Decided
- April 9, 2026
Summary
Debtor's counsel Kathleen M. Wilson admitted using generative AI to draft an Objection and Supplemental Response to a Motion for Relief from Stay in a Chapter 13 case. The pleadings cited a nonexistent case (In re Buttermilk Towne LLC), misused another (In re Garcia, with no cite), and invoked La. R.S. section 9:5774, a Louisiana statute that does not exist. Judge John W. Kolwe found a Rule 9011(b)(2) violation and concluded that Wilson's failure to verify AI-generated content caused her to file false and misleading pleadings.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $2,750
What sanction did the court impose?
$2,750 monetary sanction payable to the Clerk within ten days; six hours of in-person CLE on AI in legal practice required (including one hour of ethics and one hour of professionalism); Wilson barred from filing or participating in any new bankruptcy case in the Western District of Louisiana until both the payment and CLE proof are submitted; the Objection, Supplemental Response, and Corrected Supplemental Response all stricken.
Why does In re Troylond Malon Wise matter for law firms using AI?
In re Wise is among the first published bankruptcy court sanctions orders in the Fifth Circuit addressing generative AI hallucinations, and the court explicitly treated it as a matter of first impression and a warning shot. The conditional practice bar, withholding the right to file new cases in the district until CLE and payment are verified, is a meaningful escalation beyond a flat fine, and firms whose attorneys handle bankruptcy work in W.D. La. should treat unverified AI-assisted citations as a docket-access risk, not just a malpractice risk.
The same attorney was sanctioned two months later in Withers v. City of Aberdeen (N.D. Miss. June 8, 2026), where the Northern District of Mississippi revoked her pro hac vice admission, barred her from appearing in that district for two years, and fined her $2,500 for an AI-drafted brief filed before this order. That court cited this sanction in finding her earlier apologies insincere and her conduct an extreme dereliction of professional responsibility, while stating it could not consider that later conduct in setting its own sanction, and directed that its order be sent to the judge presiding here.