Was Rochon Eidsvig & Rochon Hafer v. JGB Collateral sanctioned over AI-generated citations?

Rochon Eidsvig & Rochon Hafer v. JGB Collateral (Texas CA, June 12, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Monetary sanction: $2,500 attorney's fees to opposing counsel, plus 8 hours CLE (3 ethics, 5 technology); brief struck. $2,500 in monetary penalties.

Which AI tool was involved in Rochon Eidsvig & Rochon Hafer v. JGB Collateral?

The order in Rochon Eidsvig & Rochon Hafer v. JGB Collateral does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

June 12, 2025 · AI sanctions database

Rochon Eidsvig & Rochon Hafer v. JGB Collateral

Rochon Eidsvig & Rochon Hafer v. JGB Collateral is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: Texas CA
Date: June 12, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Monetary sanction: $2,500 attorney's fees to opposing counsel, plus 8 hours CLE (3 ethics, 5 technology); brief struck
Penalty: $2,500 in monetary penalties.

FineProfessional sanction

What the record shows

The appellate panel found that counsel Heidi R. Hafer filed a brief citing four cases that could not be located, did not act with intent to deceive, but failed to verify the citations or correct them after opposing counsel flagged them, violating duties of competence and candor. The panel ordered her to complete eight hours of CLE (three ethics, five technology) and to pay $2,500 in attorney's fees to opposing counsel as a sanction for her misconduct.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · Texas CA

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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