Courts on AI / Fabricated or misquoted citations
San Antonio Independent School District v. Becerra
Texas Court of Appeals, Fourth District · State appellate courts · TX · · No. 04-25-00724-CV · opinion
The Texas Fourth Court of Appeals reverses denial of SAISD’s jurisdiction plea and renders dismissal. Before reaching the merits, the court identifies four hallucinated opinions in Becerra’s brief and cautions counsel that similar future issues will not be tolerated.
- Disposition
- The court reversed and rendered dismissal while admonishing Becerra's counsel about hallucinated authorities.
- Recorded conduct
- Appellee’s counsel cited three nonexistent Texas appellate opinions and misdescribed a real Fifth Circuit Cutrer employment case as school-law authority. — 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.
We begin by noting that Becerra’s appellee’s brief cites eight judicial opinions, four of which appear to be hallucinations created by generative artificial intelligence: “Alief Independent School District v. Lozano, 543 S.W.3d 118 (Tex. App.—Houston [14th Dist.] 2018, pet. denied),” cited on page 23 of Becerra’s brief, does not exist. The citation 543 S.W.3d 118 leads to a 2018 opinion from a Missouri court of appeals. ... “Hoffman v. ESD 48, No. 01-14-00676-CV (Tex. App.—Houston [1st Dist.] 2015, pet. denied),” cited on page 22 of Becerra’s brief, does not exist. ... “Neely v. West Orange-Cove Consol. ISD, No. 09-17-00196-CV (Tex. App.—Beaumont 2018, no pet.),” cited on page 21 of Becerra’s brief, does not exist. ... “Cutrer v. Tarrant County College District, 943 F.3d 265 (5th Cir. 2019),” cited on page 21 of Becerra’s brief, appears to be an attempt to cite a Fifth Circuit opinion styled Cutrer v. Tarrant County Local Workforce Development Board, 943 F.3d 265 (5th Cir. 2019). Becerra’s brief states that Cutrer “involved a college student’s expressive conduct and campus restrictions[.]” This is not correct. ... Reliance on fictitious citations and inaccurate representations about the contents of an opposing party’s brief are inconsistent with both of these duties. In light of these hallucinations, we have considered whether to strike Becerra’s brief “and proceed as if [she] had failed to file a brief.” ... However, we will proceed to the merits of this appeal without taking further action on this issue. We nevertheless caution Becerra’s counsel that we will not tolerate similar issues in any future appearances before this court.
Authorities cited in the passage: Alief Independent School District v. Lozano, 543 S.W.3d 118 · Hoffman v. ESD 48, No. 01-14-00676-CV · Neely v. West Orange-Cove Consol. ISD, No. 09-17-00196-CV · Cutrer v. Tarrant County Local Workforce Development Board, 943 F.3d 265 (5th Cir. 2019) · Suday v. Suday, 2026 WL 100418 · AGiza v. Franklin, 2025 WL 2058089 · Tex. R. App. P. 38.9
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