In re Whitehall Pharmacy LLC
U.S. Bankruptcy Court, Eastern District of Arkansas · Bankr. E.D. Ark. · Arkansas bar guidance
Verified April 26, 2026
- Citation
- In re Whitehall Pharmacy LLC, No. 4:25-bk-12406 (Bankr. E.D. Ark. Sept. 3, 2025)
- Decided
- September 3, 2025
Summary
Debtor's counsel Charles D. Davidson Sr. filed a brief in a Chapter 11 proceeding that included a citation to a nonexistent decision, "In re Berry Good, LLC," apparently produced by an unidentified generative AI tool. Bankruptcy Judge Phyllis M. Jones issued an order to show cause why sanctions should not issue. After Davidson's response and the show-cause hearing, the court entered a sanctions order resolving the matter without monetary penalty.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause withdrawn and dismissed without imposition of monetary sanctions. The court referred the matter to the Arkansas Supreme Court Committee on Professional Conduct (Office of Professional Conduct) for whatever further action that body deems appropriate.
Why does In re Whitehall Pharmacy LLC matter for law firms using AI?
Whitehall illustrates the increasingly common pattern of bankruptcy courts handling AI-fabricated citations through bar referrals rather than direct monetary sanctions. For managing partners, the practical exposure here is reputational and disciplinary: a state bar complaint opens an independent track of risk that no fee award would have created.
Sources
Primary sources
Further reading
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.