Courts on AI / Fabricated or misquoted citations

Fofanah v. Rockwall Rental Properties

Court of Appeals, Fifth District of Texas at Dallas · State appellate courts · TX · 2026-04-15 · No. No. 05-25-00536-CV · memorandum opinion

Fabricated or misquoted citations

The Texas Court of Appeals, Fifth District on 2026-04-15 affirmed summary judgment for Rockwall Rental Properties after appellants relied on unsupported and hallucinated case citations in Fofanah v. Rockwall Rental Properties. The self-represented appellant filed a reply brief with one fabricated case citation and two mischaracterized case citations, including Khan v. GBAK Properties.

Disposition: The summary judgment for Rockwall Rental Properties was affirmed after the court found no reversible error.
Recorded conduct: The Fofanahs’ pro se opening brief cited seven appellate opinions, none supporting the asserted propositions; their reply brief cited fifteen opinions, including a purported Dallas Court of Appeals opinion, Jones v. American Real Estate Services, LLC, that the court could not locate and deemed hallucinated, and four more unsupported citations. — 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.

After appellee filed its brief, cogently and logically demonstrating the lack of merit in appellants’ appellate argument and showing that the case citations briefed by appellants do not stand for the claimed propositions of law, appellants filed a replybrief. Thereplybriefattemptedtoaddanappellateissue,anditincludedfifteen opinion citations. Of those, one is a purported opinion from this court for which the citation is incorrect and which we were unable to locate after extensive research. It appears to be hallucinated. Four of the opinions cited in the reply brief do not stand for the asserted propositions. The remaining cases cited are for generic legal propositions, such as the standards for granting summary judgment. Considering the merits, we find no error and affirm the judgment. BACKGROUND On January 14, 2020, appellants executed a promissory note in favor of appellee, secured by a deed of trust against their property in Kaufman County.

Authorities cited in the passage: Appellants relied on Khan v. GBAK Properties, Inc. for a notice-of-default proposition the opinion does not support · Appellants cited 'Jones v. American Real Estate Services, LLC' as an opinion of this court

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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