Courts on AI / Fabricated or misquoted citations

Harris v. Lyotard

Court of Appeals of Texas, Fifth District, Dallas · State appellate courts · TX · 2026-06-12 · No. No. 05-24-01449-CV · opinion

Fabricated or misquoted citations

On 2026-06-12, in Shaddai Harris v. Nadia Lyotard and Mitchell Sadler, Court of Appeals of Texas struck the appellant's original briefs, required an amended brief, and then decided the appeal on the redrawn briefing. A self-represented appellant filed a reply brief using at least four nonexistent or hallucinated authorities and authorities used for propositions they did not support.

Disposition: The court reversed the intentional-infliction-of-emotional-distress judgment, rendered take-nothing relief on that claim, and otherwise affirmed; it noted earlier briefing had been stricken and redrawn.
Recorded conduct: The pro se appellant’s initial brief contained at least four hallucinated citations and at least twenty citations that did not support the cited proposition; the reply had at least two hallucinated citations and at least ten unsupported citations. The striking of the original briefing occurred by an earlier order recounted in the opinion. — 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.

–4– Appellant initially filed a brief raising sixteen appellate issues.1 The brief contained at least four hallucinated citations and at least twenty citations which do not stand for the proposition or holding for which they are presented. After appellees filed their brief, appellant filed a reply brief with at least two hallucinated citations and at least ten citations which do not stand for the proposition or holding for which they are presented. Appellees,meanwhile,filedabriefchallengingappellant’sinitialbrief,noting at least one hallucination and multiple instances of appellant misrepresenting the holdings of cited cases. Appellees’ brief itself was lacking; the brief contained exactly one citation to the record, and that citation was to the entirety of the trial court record (“see generally Clerk’s Record and Reporter’s Record”). Notably, appellees’ brief made no effort to refute appellant’s arguments about the portion of the judgment awarding appellee Lyotard damages for intentional infliction of emotional distress.

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: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document; 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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