Mills v. Rocket Mortgage LLC

What sanction did the court impose?

On November 24, 2025, District Judge Terry A. Doughty entered a Judgment (ECF No. 42) adopting the magistrate judge's R&R. The court granted the defendants' Rule 12(b)(6) and 12(b)(5) motions, denied the motions to remand, and dismissed plaintiffs' claims against all defendants with prejudice. As to the AI conduct, Judge Doughty issued a prospective warning rather than imposing current Rule 11 sanctions, "consistent with the Magistrate Judge's Report and Recommendation, the Court hereby warns Plaintiffs that any further inappropriate use of generative artificial intelligence ('GenAI') in filings before this Court 'could result in sanctions, such as the striking of their briefs, fines, or other appropriate actions.'" No monetary sanction was imposed at this stage.

Why does Mills v. Rocket Mortgage LLC matter for law firms using AI?

Mills v. Rocket Mortgage LLC is the Western District of Louisiana’s clearest published example of the magistrate-recommends / district-judge-warns sequence for pro se generative-AI fabrication. The two orders (the magistrate’s November 7, 2025 R&R at ECF 37 and Judge Doughty’s November 24, 2025 Judgment at ECF 42) operate as a single procedural unit: the magistrate makes the Rule 11 case for sanctions, and the district judge calibrates the disposition to a warning consistent with the first-occurrence pattern that has emerged across federal courts handling pro se AI-citation conduct.

Three points are notable for firms practicing in the Fifth Circuit. First, the R&R squarely rejects the “I’m pro se” defense, locating the Rule 11(b) certification in the act of presenting a brief to the court rather than in the lawyer’s signature alone. This tracks the Seventh Circuit’s 2026 holding in Jones v. Kankakee County Sheriff’s Department and the Tenth Circuit’s longstanding rule, but it is among the first published Fifth Circuit district-court statements of the proposition in an explicit GenAI context. Second, the R&R’s reference to a “comparable $2,000 penalty imposed in another case” suggests the magistrate had a specific anchor in mind for the next sanction in the district; a future pro se filer with similar conduct should anticipate that benchmark. Third, the warning’s plain text (“striking of their briefs, fines, or other appropriate actions”) tracks the language of D. Kan. Standing Order 26-01 and the W.D. La. court’s general inherent-authority framework, suggesting the next-occurrence sanction will be calibrated against actual fee award figures from the same docket rather than a flat figure.

For a Louisiana firm representing institutional lenders or servicers in pro se litigation, the operational implication is that flagging fabricated citations in a reply brief is sufficient to trigger magistrate scrutiny without a separate Rule 11 motion. The Mills sequence also confirms that when the underlying merits favor dismissal (here, on Rule 12(b)(6) and 12(b)(5) grounds, with remand denied), the AI-citation issue does not require the court to defer disposition; the magistrate can address both in the same R&R, and the district judge can affirm both in the same judgment.