Mitchell's suggestion that the "Precision" version of Westlaw, which is a generative AI tool offered by Westlaw, should be given different treatment from non-legal AI tools demonstrates Mitchell's disregard for the General Orders of the Southern District of Texas. S.D. Tex. General Order 2025-04 expressly cautions lawyers against using generative AI services without checking accuracy, and does not differentiate between legal AI services and general AI services. In fact, S.D. Tex. General Order 2025-04 mentions Harvey.AI, a legal specific AI service, as an example of an AI tool that should be used with caution. [...] Thus, whether the citations were generated by artificial intelligence, copied from prior filings without verification, or typed manually, the fundamental problem remains: Mitchell submitted citations and quotations that he had not verified and that do not support his legal contentions.
The defence here is the one every firm buying legal AI is implicitly relying on: that a tool built for lawyers and sold by a legal publisher is a different kind of thing from a general chatbot. The lawyer told the court, on information and belief, that he had the Precision version of Westlaw and that it has AI in it. The court's answer is the reason this case is on the page. Its own standing order on generative AI draws no line between legal and general services, and names a legal-specific product as an example of one to use with caution. Then it goes further and declines to decide the question at all: whether the citations came from AI, from an old template or from someone typing them, what he filed were quotations that are not in the decisions they were attributed to. Decided 14 July 2026, in an involuntary bankruptcy: a Rule 11(b) violation, six hours of continuing legal education from the State Bar of Texas on generative AI in the courts, a finding of civil contempt of an earlier order, and 29,877 US dollars in the trustee's fees. Worth being precise about one thing the order is precise about: the court made no finding that Westlaw Precision produced the citations, and the assertion that it might have was the lawyer's own.



































