James Lawrence Bryant, Jr. and Sharon Renea Bryant

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UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF NORTH CAROLINA
GREENSBORO DIVISION
In re: 	)
)
James Lawrence Bryant, Jr., 	)
Sharon Renea Bryant, 	) 	Case No. 25-10147
) 	Chapter 7
Debtors. 	)
___________________________________)
ORDER DIRECTING DEBTORS TO APPEAR AND SHOW CAUSE WHY THE COURT
SHOULD NOT SANCTION DEBTORS FOR FAILURE TO COMPLY WITH RULE 9011
This 	case 	is 	before 	the 	Court 	on 	various 	filings 	by 	James
Lawrence Bryant, Jr. and Sharon Renea Bryant (“Debtors”). 	Debtors
commenced 	this 	case 	by 	filing 	a 	voluntary 	petition 	under 	chapter
7 of title 11 on March 13, 2025. 	ECF No. 1. 	Debtors are proceeding
pro 	se. 	For 	the 	reasons 	stated 	herein, 	the 	Court 	will 	order
Debtors 	to 	appear 	on 	November 	25, 	2025, 	and 	show 	cause 	why 	the
Court 	should 	not 	sanction 	Debtors 	for 	failure 	to 	comply 	with
Federal Rule of Bankruptcy Procedure 9011.
In the last three weeks, Debtors have filed multiple documents
appearing 	to 	utilize 	generative 	artificial 	intelligence 	(GAI).
SO ORDERED.
SIGNED this 18th day of November, 2025.
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The 	filed 	documents 	include: 	a 	Motion 	to 	Set 	Aside 	Confession 	of
Judgement, 	ECF 	No. 	100; 	a 	Motion 	for 	Sanctions 	for 	Violating
Automatic Stay and Discharge Injunction, ECF No. 103; an Emergency
Motion 	to 	Stay 	and 	Quash 	Rule 	2004 	Examination, 	ECF 	No. 	106; 	a
document 	titled 	“Notice 	of 	No 	Creditor 	Standing 	and 	Satisfaction
of Judgment,” ECF No. 107; an Amended Motion to Declare Confession
of Judgment Void and to Disallow Associated Claim, ECF No. 111; a
Motion 	to 	Avoid 	Judicial 	Lien, 	ECF 	No. 	116; 	a 	Motion 	to 	Confirm
Allowance and Finality of Homestead Exemption, ECF No. 117; and a
Reply in Support of Motion for Sanctions. 	ECF No. 128.
Several 	of 	these 	filings 	request 	duplicative 	relief 	and
contain 	false 	or 	misleading 	case 	citations, 	also 	known 	as
“hallucinations.”1 	For example, in the Amended Motion to Declare
Confession of Judgment Void and to Disallow Associated Claim, ECF
No. 111, Debtors cite to “Pulley v. Pulley,2 254 N.C. 714 (1961),”3
1 See In re Richburg, 671 B.R. 918, 924 n.11 (Bankr. D.S.C. 2025)(citing Conor
Murray, Why AI “Hallucinations” Are Worse Than Ever, FORBES (May 6, 2025, 1:12
PM), 	https://www.forbes.com/sites/conormurray/2025/05/06/why-ai-
hallucinations-are-worse-than-ever/ (“noting that ‘[q]uestions asked outside of
the 	data 	the 	AI 	model 	knows 	can 	lead 	to 	the 	bot 	responding 	with 	incorrect
information,’ 	and 	reasoning 	models 	like 	ChatGPT 	and 	OpenAI 	are 	‘designed 	to
maximize the chance of giving an answer, meaning the bot will be more likely to
give an incorrect response than admit it doesn't know something’”)).
2 	All 	cases 	cited 	to 	in 	bold 	indicate 	that 	the 	citations 	are 	inaccurate 	or
wholly non-existent.
3 Pulley v. Pulley’s correct citation is Pulley v. Pulley, 255 N.C. 423 (1961)
(reversing the trial court judgment determining that the confession of judgment
was invalid due to the payment of a portion of the obligation evidenced by the
judgment prior to recording the judgment, and holding that debtor was estopped
from questioning the validity of his own confession of judgment for alimony).
While the citation is inaccurate, Debtors are correct that Pulley v. Pulley,
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“Harrison 	v. 	Hinson, 	338, 	352 	S.E.2d 	836 	(1987),”4 	and 	“In 	re
Weiman, 22 F.3d 135 (7th Cir. 1994)”.5 	None of the citations above
exist 	as 	cited, 	and 	neither 	“Harrison” 	nor 	“Weiman” 	support 	the
proposition for which Debtors cite them. 	Debtors also cite to “In
re 	Schmid, 	No. 	10-12142, 	2013 	WL 	4835463 	(Bankr. 	W.D. 	Wis. 	Sept.
5, 	2013),” 	which 	is 	not 	an 	authentic 	Westlaw 	citation, 	and 	the
orders 	in 	the 	actual 	Schmid 	case 	do 	not 	support 	the 	proposition
for which Debtors offer in this case.6 	Similarly, in the Emergency
does support that a confession of judgment must “show the consideration, and
the amount confessed as justly due . . . .” 	255 N.C. at 879-80.
4 “Harrison v. Hinson” does not exist. 	It appears that the correct citation is
Harris v. Hinson, 360 S.E.2d 118 (N.C. Ct. App. 1987) (holding that under N.C.
Gen. Stat. § 1–362, a “judgment debtor can receive his salary, and dispose of
it in any manner he chooses, regardless of whether it contains an amount of
funds in excess of what is required to satisfy his and his family's reasonable
living expenses”). 	Debtors cite “Harrison” for the proposition that, in North
Carolina, 	“stipulated-damages 	clauses 	are 	enforceable 	[only] 	when 	they
represent a reasonable forecast of probable loss and not when they function as
a penalty to compel.” 	ECF No. 111, at 6. 	However, in Hinson the underlying
judgment 	derived 	from 	a 	jury 	verdict 	and 	not 	a 	contract 	with 	a 	stipulated
damages clause. 	360 S.E.2d at 119.
5 The caption of the case with the citation provided is Kirk v. Fed. Prop. Mgmt.
Corp., 	22 	F.3d 	135 	(7th 	Cir. 	1994) 	(holding 	that 	the 	Defendant 	failed 	to
establish a prima facie case of 	employment discrimination under 42 U.S.C. §
2000e–2(a)(1), among other things). 	Debtors cite Kirk is inapposite to the
matters raised in this case.
6 Seeking to have this Court set aside the Confession of Judgment, Debtors in
this case attempt to take a direct assault on the state court judgment by asking
this Court to declare it void and vacate it, see No. 25-10147, ECF No. 111,
citing “Schmid.” 	In Schmid, the only order dated September 5, 2013, is an order
denying the prior motion to reconsider the court’s prior order overruling the
debtor’s objection to a claim. 	In re Schmid, Case No. 1-10-12142-cjf, ECF No.
190 (Bankr. W.D. Wis. Sep. 5, 2013). 	The original order determined that the
court was bound by a prior state court determination of the contested issues
under both the Rooker-Feldman doctrine and issue and claim preclusion. 	The
original order is a reported decision. 	See In re Schmid, 494 B.R. 737, 750
(Bankr. W.D. Wis. 2013) (holding, inter alia, that, where debtor objected to
the standing of a creditor after a state court determined that the creditor was
the proper holder of the mortgage, the issue of the creditor’s standing was
unreviewable under the Rooker-Feldman doctrine and preclusion).
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Motion 	to 	Stay 	and 	Quash 	Rule 	2004 	Examination, 	ECF 	No. 	106,
Debtors cited to In re Symington, 209 B.R. 678, 689 (Bankr. D. Md.
1997), while that case exists, the quote Debtors attribute to that
case does not.
Federal Rule of Bankruptcy Procedure 9011(b) provides that:
By presenting to the court a petition, pleading, written
motion, 	or 	other 	document—whether 	by 	signing, 	filing,
submitting, 	or 	later 	advocating 	it—an 	attorney 	or
unrepresented 	party 	certifies 	that, 	to 	the 	best 	of 	the
person's knowledge, information, and belief formed after
an inquiry reasonable under the circumstances . . . (2)
the 	claims, 	defenses, 	and 	other 	legal 	contentions 	are
warranted by existing law or by a nonfrivolous argument
to 	extend, 	modify, 	or 	reverse 	existing 	law, 	or 	to
establish new law.
Fed. R. Bankr. P. 9011(b). 	In deciding cases based on violations
of Rule 9011, courts may look to cases that interpret Federal Rule
of Civil Procedure 11. 	In re Weiss, 111 F.3d 1159, 1170 (4th Cir.
1997).
Bankruptcy 	Rule 	9011, 	like 	Rule 	11, 	empowers 	a 	bankruptcy
court 	to 	enter 	an 	order 	describing 	the 	specific 	conduct 	that
appears to violate subdivision 9011(b) and directing that party to
show cause why it has not violated (b). 	Fed. R. Bankr. P. 9011.
In determining whether a signatory violated Rule 11, the
court 	must 	apply 	an 	objective 	standard 	of
reasonableness. 	See Robeson Defense Comm. v. Britt (In
re 	Kunstler), 	914 	F.2d 	505, 	514 	(4th 	Cir.1990). 	The
fact [that a litigant is] pro se in the proceedings . .
. 	does 	not 	change 	[the] 	analysis. 	Rule 	9011 	does 	not
exempt 	pro 	se 	litigants 	from 	its 	operation; 	a 	pro 	se
litigant 	has 	the 	same 	duties 	under 	Rule 	9011 	as 	an
attorney.
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Weiss, 111 F.3d at, 1170; see also In re Burse, 120 B.R. 833, 837
(Bankr. E.D. Va. 1990).
If a court determines that sanctions are appropriate, because
a 	provision 	of 	Rule 	9011(b) 	was 	violated, 	it 	may 	“impose 	an
appropriate 	sanction 	on 	any 	. 	. 	. 	party 	that 	committed 	the
violation 	[under 	subdivision 	(b)] 	. 	. 	. 	.” 	Fed. 	R. 	Bankr. 	P.
9011(c). 	Sanctions 	under 	Rule 	9011 	are 	limited 	to 	what 	is
sufficient 	to 	deter 	repetition 	or 	comparable 	conduct, 	and 	those
sanctions can include striking motions and monetary relief, among
other 	things. 	Green 	v. 	Prince 	George's 	Cnty. 	Off. 	of 	Child
Support, 	641 	B.R. 	820, 	840–41 	(D. 	Md. 	2022), 	aff'd, 	No. 	22-1705,
2023 	WL 	3051812 	(4th 	Cir. 	Apr. 	24, 	2023) 	(“Sanctions 	should 	be
sufficient 	to 	serve 	the 	purposes 	of 	Rule 	9011, 	but 	not 	greater
than necessary to deter abuse.” (citation omitted)).
Debtors’ citation errors are emblematic of GAI, which is known
to “hallucinate” nonexistent cases and law.7 	While this technology
may be beneficial and assist in the preparation of court filings,
even pro se plaintiffs must perform a reasonable inquiry under the
circumstances that the claims defenses and other legal contentions
are warranted and nonfrivolous. 	Fed. R. Bankr. P. 9011; see, e.g.,
O'Brien 	v. 	Flick, 	No. 	24-61529-CIV, 	2025 	WL 	242924, 	at 	*7 	(S.D.
7 See In re Martin, 670 B.R. 636, 647 n.7 (Bankr. N.D. Ill. 2025) (collecting
cases 	discussing 	the 	pitfalls 	of 	generative 	AI 	usage 	and 	imposing 	$5,500
sanction against counsel for filing documents containing hallucinations).
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Fla. 	Jan. 	10, 	2025), 	aff'd, 	No. 	25-10143, 	2025 	WL 	2731627 	(11th
Cir. 	Sep. 	25, 	2025). 	“At 	the 	very 	least, 	the 	duties 	imposed 	by
Rule 	11 	require 	that 	attorneys 	read, 	and 	thereby 	confirm 	the
existence 	and 	validity 	of, 	the 	legal 	authorities 	on 	which 	they
rely.” 	Martin, 	670 	B.R. 	at 	642-43 	(quoting 	Benjamin 	v. 	Costco
Wholesale 	Corp., 	779 	F. 	Supp. 	3d 	341, 	347 	(E.D.N.Y. 	2025)).
Unrepresented parties have the same minimum obligations.
The 	Court 	recognizes 	that 	GAI 	offers 	significant 	benefit 	in
providing 	unrepresented 	parties 	access 	to 	justice. 	This 	access,
however, 	comes 	with 	the 	responsibility 	for 	unrepresented 	parties
to ensure that filings comply with applicable standards, including
Rule 9011. 	To rule otherwise, would relieve unrepresented parties
from the obligations clearly imposed by that rule, and would place
an unbearable burden on the Courts and opposing parties.
Thus, 	even 	unrepresented 	litigants 	are 	required 	to
independently verify that the cases represented therein exist and
support the proposition for which they are cited. 	Fed. R. Bankr.
P. 	9011(b). 	Debtors’ 	filings 	are 	based 	in 	part 	on 	non-existent
case law and case law which supports propositions wholly opposite
to 	those 	for 	which 	Debtors 	offer 	them. 	Further, 	Debtors 	filings
seek overlapping and duplicative relief. 	See, e.g., ECF No. 103;
ECF 	No. 	111. 	The 	numerous 	and 	continuous 	filings 	containing
arguments 	and 	citations 	that 	violate 	Rule 	9011 	imposes 	an 	undue
and untenable burden on the Court and opposing parties. 	Therefore,
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the 	Court 	will 	order 	Debtors 	to 	appear 	on 	November 	25, 	2025, 	and
show 	cause 	why 	the 	Court 	should 	not 	sanction 	Debtors 	through 	its
inherent powers, 11 U.S.C. § 105, and Rule 9011(c) for failure to
comply 	with 	Rule 	9011. 	Such 	sanctions 	may 	include 	monetary
sanctions, 	striking 	of 	documents 	from 	the 	record, 	and 	denial 	of
relief requested in violative documents.
NOW, 	THEREFORE, 	IT 	IS 	HEREBY 	ORDERED, 	ADJUDGED, 	and 	DECREED
as follows:
1. 	Debtors must appear and show cause why the Court should
not sanction Debtors for failure to comply with Rule 9011.
2. 	The Court will conduct the hearing as follows:
DATE: 	November 25, 2025
TIME: 	9:30 am
LOCATION: 	Second Floor, Courtroom # 1
South Edgeworth Street
Greensboro, NC 27401
[END OF DOCUMENT]
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Parties to be Served
25-10147
John Paul Hughes Cournoyer
Bankruptcy Administrator 	Via CM/ECF
Vicki L. Parrott
Chapter 7 Trustee 	Via CM/ECF
James Lawrence Bryant, Jr.
Sharon Renea Bryant
5629 Siler Street
Trinity, NC 27370
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