Courts on AI / Fabricated or misquoted citations

Crawford v. Buffalo Creek Properties, LLC

Court of Appeals of Texas, Austin · State appellate courts · TX · 2026-04-23 · 2026 WL 1097101 · No. No. 03-24-00260-CV · memorandum opinion

Fabricated or misquoted citations

The Texas Court of Appeals on 2026-04-23 affirmed the judgment for Buffalo Creek after finding no reversible error and noting unsupported or nonexistent authorities in the brief in Joann Crawford v. Buffalo Creek Properties, LLC. The self-represented party filed a brief with two fabricated case citations and one invented legal doctrine, including Hercenberger v. Proctor' without a reporter citation.

Disposition: The judgment granting specific performance was affirmed; the court noted unsupported or hallucinated authorities but imposed no consequence for them.
Recorded conduct: Crawford’s pro se brief cited cases that were either hallucinated or did not support the asserted contract proposition; examples included an In re Estate of Denman citation pointing to an Arkansas criminal case and an uncited Hercenberger v. Proctor authority the court could not verify. — outcome: noted, no consequence; actor: litigant in person
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.

She does not specify in her brief what amendment she refused to accept. She cites cases that she purports support the proposition that any amendments to the Contract had to be in writing. However, Crawford's cited cases are either “hallucinated” cases or do not support the proposition that the mere proposal of an amendment nullified the Contract. 5 Regardless of what amendment Crawford disputes, Buffalo Creek sought specific performance of the original Contract, and the court awarded that relief. There is no showing that the court ordered specific performance of any amendment Buffalo Creek proposed. The Contract called for any liens or binding agreements to be “satisfied out of the sales price. ” The court “reformed” the Contract to adjust Buffalo Creek's payment due for the expenses of effectuating the Contract such as courts costs, attorney's fees, property-tax payments, and payment to the life-estate holder.

Authorities cited in the passage: Appellant referenced 'Hercenberger v. Proctor' without a reporter citation

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: ; court site blocks automated access (checked search.txcourts.gov) Official copy not obtained 2026-09-08: court site blocks automated access (checked search.txcourts.gov) (checked search.txcourts.gov). Re-coded from the document 2026-09-08 (independent second read).

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