Kattom v. Bondi (Mar. 6, 2026)

Case details
Country
United States
Jurisdiction
Federal
Decided
Mar. 6, 2026
AMJAD MUTIE KATTOM #045227170 v. PAMELA BONDI ET AL, Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 637419Only the Westlaw citation is currently available.United States District Court, W.D. Louisiana,ALEXANDRIA DIVISION.AMJAD MUTIE KATTOM #045227170v.PAMELA BONDI ET ALCIVIL ACTION NO. 25-1497 SEC P|Filed 03/06/2026Attorneys and Law FirmsKenneth A. Mayeaux, Mayeaux & Assoc, Baton Rouge, LA,for Amjad Mutie Kattom #045227170.Jabrina Clayton Edwards, DOJ-United States Attorney'sOffice, Shreveport, LA, for Pamela Bondi, Kristi Noem, ScottLadwig.ORDER AND REASONSJERRY EDWARDS, JR. UNITED STATES DISTRICTJUDGE*1 The Court ordered Kenneth Mayeaux (“Mayeaux”),counsel for Petitioner, to show cause why he should not besanctioned pursuant to (1) Fed. R. Civ. P. 11(b), (c) and (2) 28U.S.C. § 1927 for filing a Motion for Temporary RestrainingOrder and accompanying Memorandum without verifyingthe accuracy of the citations therein. See R. Doc. 14 at 4.Specifically, as summarized in this Court's Order (R. Doc.14), Mayeaux cited several incorrect quotations and to casesthat did not exist. See id. at 3–4. The Court must now addressthe applicable sanctions for Mayeaux's hallucinated cases.Having carefully considered Mayeaux's submissions and theapplicable law, this Order follows.On December 8, 2025, Mayeaux responded to this Court'sOrder. R. Doc. 17. At the outset, Mayeaux took responsibilityand acknowledged the seriousness of his actions. See id. at1, 6. Mayeaux informed the Court that Petitioner contactedMayeaux in the late afternoon of November 17, 2025. Seeid. at 2. Based on Petitioner's representations during thisconversation and Mayeaux's previous experience, Mayeauxbelieved that Petitioner's removal was imminent. See id.Thus, Mayeaux began drafting the Motion for TemporaryRestraining Order to prohibit Petitioner's removal, see id.at 3, which was filed on the morning of November 18,2025. See R. Doc. 13. Mayeaux used ChatGPT, an artificial-intelligence (“AI”) tool, to draft the memorandum in supportof Petitioner's Motion. See R. Doc. 17 at 4. Despite neverhaving used generative AI, Mayeaux understood the risksassociated with its use, including the potential for generatinginaccurate or fabricated legal authority. See id. Mayeaux nowadmits to not fully vetting or verifying the governing law orthe citations within the submitted memorandum. See id. Healso asserts that he should be sanctioned but in a proportionalsense, given that “he acted without deceptive intent, correctedthe error immediately upon discovery, [took] steps to preventrecurrence, and has extreme remorse for his actions.”1 Seeid. at 6. Mayeaux requests that, in light of these mitigatingfactors, the Court impose a $1,000 sanction. See id. at 12–13.Now, like many other district courts in the Fifth Circuit,the Court is “buden[ed] [with] addressing AI hallucinationsin court filings.” Fletcher v. Experian Info. Sols., Inc.,No. 25-20086, 2026 WL 456842, at *2 (5th Cir. Feb. 18,2026) (collecting cases). Regardless of whether a lawyeruses AI or not, the lawyer's duty remains unchanged ashe “must ‘ensure that the legal propositions and authoritygenerated are trustworthy.’ ” See id. (quoting ByoPlanet Int'l,LLC v. Johansson, 792 F. Supp. 3d 1341, 1347 (S.D. Fla.2025)). Just as the duty remains unchanged, so too do thestandards for assessing sanctions applicable to a lawyer's useof hallucinated cases. See id. at **5–6 (internal citations andquotations omitted); see also Lee v. R&R Home Care, Inc.,No. CV 24-836, 2025 WL 2481375, at **2–4 (E.D. La. Aug.28, 2025) (reviewing Federal Rule of Civil Procedure 11'sgovernance of sanctions and ordering a $1,000 sanction forattorney's use of hallucinated cases).*2 The Court commends Mayeaux for his candor, honesty,and the remedial measures he has undertaken since the filingof the underlying Motion. But these mitigating factors do notexcuse Mayeaux's conduct. At minimum, Rule 11 requiresattorneys to verify the accuracy of submissions to the Court.See Nora v. M & A Transp., Inc., No. CV 25-1015, 2025WL 2337132, at *3 (E.D. La. Aug. 13, 2025) (“At the veryleast, the duties imposed by Rule 11 require that attorneysread, and thereby confirm the existence and validity of, thelegal authorities on which they rely.”) (internal citations andquotations omitted). In its discretionary authority under Rule
AMJAD MUTIE KATTOM #045227170 v. PAMELA BONDI ET AL, Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.2112, the Court will impose a monetary sanction in the amountof $1,000.IT IS ORDERED that Kenneth A. Mayeaux is personallySANCTIONED for his conduct in this case in the amountof $1,000. This amount must be paid by Mayeaux personallyand may not be paid by his law firm.IT IS FURTHER ORDERED that the sanction is to be paidby Friday, April 3, 2026, at 5:00 p.m. to:Clerk, United States District Court, Western District ofLouisiana, 515 Murray Street, Suite 105 Alexandria,Louisiana 71301THUS DONE AND SIGNED in Chambers this 6th day ofMarch, 2026.All CitationsSlip Copy, 2026 WL 637419Footnotes1Specifically, Mayeaux assets that “[h]e has undertaken concrete remedial measures, including enrolling in CLEs on AI-assisted legal practice, review of governing ethical guidance, and developing strengthened verification protocols to ensurethat all authorities are independently confirmed before filing ....” See id. at 12.2Rule 11(b) provides that an attorney's signature on a written motion represents that the attorney's claims or legalcontentions were warranted by existing law. See Fed. R. Civ. P. 11(b)(2). Upon a violation of Rule 11(b), Rule 11(c)provides discretion to the Court to issue an appropriate sanction on the attorney. See Fed. R. Civ. P. 11(c)(1).End of Document© 2026 Thomson Reuters. No claim to original U.S.Government Works.
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