Kattom v. Bondi
U.S. District Court, Western District of Louisiana, Alexandria Division · W.D. La. · Louisiana bar guidance
Verified May 5, 2026
- Citation
- Kattom v. Bondi, No. 25-1497 (W.D. La. Mar. 6, 2026), 2026 WL 637419
- Decided
- March 6, 2026
Summary
Attorney Kenneth A. Mayeaux used ChatGPT to draft a memorandum supporting an emergency Motion for Temporary Restraining Order to prevent his client's imminent removal. The filing contained incorrect quotations and citations to cases that did not exist. Mayeaux, who had never previously used generative AI, admitted he failed to verify the governing law or citations and accepted responsibility. Judge Jerry Edwards, Jr. imposed sanctions under Fed. R. Civ. P. 11 after a show-cause process.
- AI tool:
- ChatGPT
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 monetary sanction imposed personally on Mayeaux, payable by him and not his law firm, due to the Clerk by April 3, 2026. The court credited Mayeaux's candor, immediate correction, and remedial measures (CLE enrollment, ethics review, new verification protocols) as mitigating factors supporting the proportional amount he requested.
Why does Kattom v. Bondi matter for law firms using AI?
Kattom illustrates how Rule 11 sanctions land on a first-time AI user who self-reports and remediates: still a $1,000 personal-pay sanction, no firm indemnification, and a published order naming the lawyer. For a managing partner, the takeaway is that candor and CLE enrollment mitigate but do not eliminate exposure, and emergency-filing time pressure (here, an imminent removal) is not a recognized excuse for skipping citation verification.
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.