Holding / Framework
Establishes the BIGLAW BANKRUPTCY-PRACTICE FRAMEWORK: large law firms practicing in bankruptcy court face the same Rule 9011 duties as solo practitioners and small firms, and pre-paying sanctions to avoid a hearing does not insulate counsel from public reprimand. The supplemental-brief 'obdurately clung' language signals an additional doctrinal element: failure to retract or correct after notice may itself constitute compounding misconduct, paralleling the Crabill compounding-misconduct framework.
Triggering Conduct
Senior counsel at Gordon Rees Scully Mansukhani filed briefs containing citations that did not stand for the propositions cited, did not contain the quotes attributed to them, or did not exist at all. A supplemental brief 'obdurately clung' to prior positions and 'continued to miscite authorities,' compounding the misconduct.
Sanctions / Disposition
Gordon Rees Scully Mansukhani LLP paid $55,721.20 in fees sought in the Motions for Sanctions, without contesting a hearing. Senior counsel publicly reprimanded by the bankruptcy court. (Notable: the firm is among the 100 largest American law firms by Bloomberg Law's accounting.)
Primary Source
https://news.bloomberglaw.com/bankruptcy-law/bankruptcy-judge-reprimands-ex-gordon-rees-lawyer-for-ai-citations · secondary_aggregator (Bloomberg Law / Reason.com); primary docket pull pending
Tags
11th_circuit, bankruptcy_court, hallucinated_citations, gordon_rees, biglaw, public_reprimand, rule_9011, framework_setter, supplemental_brief_doubling_down, compounding_misconduct