govinfo:USCOURTS-laed-2_25-cv-00804-0

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UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF LOUISIANA 
 
TAIUJUAN BURCHES, 
 Plaintiff 
CIVIL ACTION 
 
 
VERSUS 
 
NO. 25-804 
 
EQUIFAX INFORMATION 
SERVICES, LLC, ET AL., 
 Defendants 
SECTION: “E” (5) 
 
 
ORDER AND REASONS 
 The Court ordered Taiujuan Burches to ap pear and show cause why he should not 
be sanctioned for his failure to comply with Federal Rule of Civil Procedure 11(b)(2). Mr. 
Burches appeared before the Court on Monday, May 11, 2026, at 9:00 a.m. 
BACKGROUND 
Plaintiff has repeatedly filed briefs containing fabricated, inaccurate, or unverifiable 
legal citations. The issue first arose in connection with Plaintiff’s Motion for Leave to File a 
Third Amended Complaint,1 when Defendant Trans Union LLC (“Trans Union”) filed an 
Ex Parte Motion for Leave to File a Surreply, 2 representing that “[a] closer examination 
of Plaintiff’s Motion reveals Plaintiff’s relian ce on fabricated and/or non-existent legal 
authorities.”3 The Court granted the Motion, 4 and Trans Union’s Surreply was filed onto 
the record. 5 The Court then set oral argument on the Motion. 6 Before oral argument, 
Plaintiff filed a Notice of Clarification admitting the citations in his Reply were fabricated 
and apologizing for the error.7 
 
1 R. Doc. 169. 
2 R. Doc. 188. 
3 Id. at p. 2. 
4 R. Doc. 189. 
5 R. Doc. 190. 
6 R. Doc. 195. 
7 R. Doc. 200. 

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At oral argument, the Court addressed th e admittedly fabricated citations with 
Plaintiff.8 The Court declined to sanction Plaintiff at that time based on his pro se status 
but cautioned Plaintiff that any future filings containing fabricated citations would result 
in sanctions against him personally. 9 The Court then ordered Plaintiff to review all his 
filings in this action to date to determine whether any other citations he had included in 
his previous filings were “fa bricated” and to send a letter to the Court by Monday, 
November 24, 2025, at 5:00 p.m., informing the Court of the resu lts of his review. 10 
Plaintiff sent an email to the Court on Nove mber 23, 2025, in which he identified three 
additional incorrect citations and fabrications in his various filings.11 
Despite that warning, Plaintiff filed an O pposition to Comenity Bank’s Motion to 
Compel Arbitration containing additional incorrect citations and fabrications.12 On March 
2, 2026, the Court ordered Plaintiff to appear on Monday, May 11, 2026, at 9:00 a.m., to 
show cause as to why he should not be sanc tioned for his failure to comply with Federal 
Rule of Civil Procedure 11(b)(2) by signing an d filing the Memorandum in Opposition to 
Comenity Bank’s Motion to Compel Arbitr ation without verifying the accuracy of 
quotations, holdings, and citations therein.13 Specifically, the Court requested clarification 
on the source of Plaintiff’s quoted language from the Fifth Circuit in Will-Drill Resources, 
Inc. v. Samson Resources Co.14 and the purported holding of Hays v. HCA Holdings, Inc.15 
After the Court issued the show-cause order, Plaintiff filed another memorandum, 
this time in opposition to Defendant Trans Union LLC’s Motion to Stay Discovery,16 citing 
 
8 R. Doc. 218. 
9 Id. at p. 2. 
10 Id. 
11 R. Doc. 311-1. 
12 R. Doc. 271. 
13 R. Doc. 293. 
14 Id. 
15 Id. 
16 R. Doc. 303. 

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Turner v. Murphy Oil USA, Inc. , 2006 WL 1984362 (E.D. La. July 13, 2006). The Court 
was unable to locate any case corresponding to that Westlaw citation, and the district 
court record in Turner case, No. 05-4206, does not reflect an order dated July 13, 2006. 
LEGAL STANDARD 
 Federal Rule of Civil Procedure 11 govern s the signing of pleadings, motions, and 
other papers, representations to the Court, and sanctions. Rule 11(b) states that 
(b) By presenting to the court a pleading, written motion, or other paper--
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 afte r an inquiry reasonable under the 
circumstances 
 
(2) the claims, defenses, and other legal contentions are warranted 
by existing law or by a nonfrivolous argument for extending, 
modifying, or reversing existing law or for establishing new law.
17 
 
Pursuant to Rule 11(c)(1), “[i]f, after notice and a reasonable opportunity to respond, the 
court determines that Rule 11(b) has been violated, the court may impose an appropriate 
sanction on any attorney, law firm, or party that violated the rule or is responsible for the 
violation.” Pursuant to Rule 11(c)(3), “[o]n its own, the court may order an attorney, law 
firm, or party to show cause why conduct sp ecifically described in the order has not 
violated Rule 11(b).”
18 Pursuant to Rule 11(5)(B), “[t]he court must not impose a monetary 
sanction . . . on its own, unless it issued the show-cause order under Rule 11(c)(3) before 
voluntary dismissal or settlement of the claims made by or against the party that is, or 
whose attorneys are, to be sanctioned.”19 
LAW AND ANALYSIS 
Before sanctioning an attorney, the Cour t must comply with the mandates of due 
 
17 FED. R. CIV. P. 11(b)(2). 
18 Id. at (c)(3). 
19 Id. at (5)(B). 

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process, which demand that the party subject to potential sanctions receive notice and an 
opportunity to be heard.20 The Court ordered Mr. Burches to appear on May 11, 2026, to 
show cause why sanctions should not be imposed. 21 The Court provided Mr. Burches 
notice of the specific conduct at issue and an opportunity to be heard. 
The Court finds Mr. Burches’s conduct vi olated Rule 11(b)(2). In determining 
whether an unrepresented party has complied with Rule 11, courts apply “an objective, 
not a subjective, standard of reasonableness.” 22 “[T]he central purpose of Rule 11 is to 
deter baseless filings in district court and . . . streamline the administration and procedure 
of the federal courts.” 23 “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.”24 
At the show cause hearing, Mr. Burches admitted to signing and filing multiple 
briefs without verifying the accuracy of th e citations contained in those briefs. Mr. 
Burches had previously been expressly warned that further filings containing fabricated 
citations would result in personal sanctions, 25 and he represented to the Court that he 
would ensure all future filings contained only accurate and verified citations. 26 Despite 
that warning and representation, Mr. Burches again submitted briefing containing 
inaccurate citations that he had not verified. Moreover, afte r the Court issued its March 
2, 2026, Order identifying the citations at issue, Mr. Burches filed yet another brief 
 
20 Id. at (c). 
21 R. Doc. 293; R. Doc. 311. 
22 Snow Ingredients, Inc. v. SnoWizard, Inc., 833 F.3d 512, 528 (5th Cir. 2016) (citing Whitehead v. Food 
Max of Miss., Inc., 332 F.3d 796, 802 (5th Cir. 2003) (en banc)). 
23 Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 393 (1990). 
24 Gauthier v. Goodyear Tire & Rubber Co. , No. 23-00281, 2024 WL 4882651, at *2 (E.D. Tex. Nov. 25, 
2024) (first quoting Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024); then citing Mata v. Avianca, Inc., 678 
F. Supp. 3d 443, 448 (S.D.N.Y. 2023)). 
25 R. Doc. 218 at p. 2. 
26 R. Doc. 311-1 at p. 2. 

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containing a citation the Court could not verify. 
The repeated submission of false or unveri fiable legal authority, particularly after 
an express warning from the Court, falls be low the objective standard of reasonableness 
required by Rule 11. Such conduct undermin es the Court’s confidence in Mr. Burches’s 
filings, imposes unnecessary burdens on the Court and opposing parties, and interferes 
with the orderly administration of justice. Sanctions are therefore warranted under Rule 
11. Plaintiff was expressly warned at the hearing, and is warned again by this Order, that 
any future filing containing fabricated authorities, miscited holdings, or false quotations 
may result in sanctions, including dismissal of this action. 
Accordingly, 
 IT IS ORDERED that Taiujuan Burches is SANCTIONED for the 
aforementioned conduct in the amount of $500. 
IT IS FURTHER ORDERED that the sanction is to be paid by June 10, 2026, 
to: 
Clerk, United States District Court 
Eastern District of Louisiana 
500 Poydras Street, Room C151 
New Orleans, Louisiana 70130 
 
 
New Orleans, Louisiana, this 11th day of May, 2026. 
 
 
________________________________ 
SUSIE MORGAN 
UNITED STATES DISTRICT JUDGE 
 
 
Clerk to Provide Copy by Mail and Email to: 
 
Taiujuan Burches 
42520 Richard Road 
Ponchatoula, LA 70454 
taiujuan87@gmail.com 

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