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Courts on AI / Fabricated or misquoted citations

In re Miller

Court of Appeals of Texas, Dallas · State appellate courts · TX · · 2026 WL 1137938 · No. No. 01-26-00319-CV · concurrence

The Texas Court of Appeals on 2026-04-23 warned counsel to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in IN RE PAULA M. MILLER, Relator. Counsel filed a submission with one fabricated case citation and one false case quotation.

Disposition
A concurrence warned that the mandamus petition appeared to contain AI-fabricated hallucinations and that such filings can lead to striking the brief and State Bar reporting.
Recorded conduct
The mandamus petition had attributions and quotations to caselaw that the concurring chief justice said strongly appeared to be AI-fabricated hallucinations with fictitious or misleading citations. — outcome: warning; actor: lawyer
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

IN RE PAULA M. MILLER, Relator NO. 01-26-00319-CV | Opinion issued April 23, 2026 Original Proceeding on Petition for Writ of Mandamus Panel consists of Chief Justice Adams and Justices Caughey and Morgan. Adams, C. J. , concurring. CONCURRING OPINION Terry Adams Chief Justice *1 I write separately to note that the mandamus petition herehasattributionsandquotationstocaselawwhichstrongly appear to be AI-fabricated hallucinations. Filing a document in our Court with fictitious or misleading citations—whether generated by AI and not checked by a human, or otherwise— is a serious breach of candor that this Court cannot tolerate. See TEX. R. APP. P. 38. 1, 38.

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