Bankruptcy Judge Reprimands Ex-Gordon Rees Lawyer for AI Citations

A bankruptcy judge publicly reprimanded a former Gordon Rees Scully Mansukhani senior counsel for submitting filings with artificial-intelligence generated fake citations, although the firm itself avoided court sanctions.

Judge Christopher L. Hawkins of the US Bankruptcy Court for the Middle District of Alabama said in a 32-page opinion late Thursday that Cassie Preston, who represented creditor Progressive Perfusion Inc. in the bankruptcy of Jackson Hospital & Clinic, “doubled down, tripled down, and quadrupled down on arguments unsupported by the authorities cited, diverting time, money, and attention from the debtors’ efforts at rehabilitation.”

The opinion follows an Oct. 28 show cause hearing after Jackson Hospital and its lender accused the firm and Preston of submitting fabricated information. The court also found misleading and fabricated citations.

“The use of generative artificial intelligence to multiply the proceedings in this case was particularly egregious,” Hawkins said in the opinion, given that the hospital, its lender, and also the court “repeatedly pointed out the very serious flaws in Progressive’s arguments and authorities.”

The AI-related violations fall under Rule 9011, which requires attorneys to certify that their filings are accurate.

Preston is no longer with the firm. Her attorney, Wallace D. Mills PC, didn’t respond to a request for comment.

Gordon Rees became the latest and largest law firm under scrutiny in bankruptcy court as Hawkins joined other bankruptcy judges in Illinois and South Carolina who recently sanctioned attorneys for submitting filings with hallucinated citations.

The judge ordered Preston to give the sanctions opinion to all clients, opposing counsel, and judges in any active cases she’s handling within 30 days, and to certify her compliance within 24 hours after doing so. The court will publish the reprimand.

Preston must provide a list of all jurisdictions where she’s licensed within 24 hours. The clerk will also send the opinion to the bar authorities in Alabama and Georgia, where she’s based, and to any other relevant jurisdictions for further action.

Days before the show cause hearing, Gordon Rees reimbursed more than $55,000 in legal fees to the law firms representing Jackson Hospital and its lender after they accused the firm and Preston of AI misuse.

Gordon Rees also expanded AI-related training and adopted a “cite checking policy” in September, requiring all briefs to be reviewed to confirm that cases are valid and citations are accurate.

Hawkins said during the hearing that the firm’s voluntary payment of the legal fees “evidences the firm’s recognition that these are serious issues.”

Gordon Rees initially denied using AI in the Jackson Hospital case, but later admitted the misuse, saying that professional and ethical duties are violated “when lawyers are not candid” with the court in their filings and responses to questions.

The firm wasn’t sanctioned, but it must give all its attorneys a copy of the opinion, along with its updated AI and citation-checking policies, obtain their acknowledgments, and certify to the court within 24 hours after completing this within 30 days.

Gordon Rees and its counsel, Copeland, Franco, Screws & Gill PA, didn’t respond to a comment request.

Preston represented Progressive Perfusion at the request of a “close personal and family friend,” according to court documents,knowing she lacked expertise on the issue before the court. Her legal work has primarily focused on insurance defense, coverage, and contractual disputes.

Her lawyer said in court filings that when questioned about the AI misuse, Preston “improperly became defensive and was not fully truthful out of fear.” He said she understood the poor decision and it was “out of character for her.”

Burr & Forman LLP represents Jackson Hospital. Kilpatrick Townsend & Stockton LLP and Wallace, Jordan, Ratliff & Brandt LLC represent the lender.

The case is Jackson Hosp. & Clinic Inc., Bankr. M.D. Ala., No. 25-30256, 11/21/25.