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San Antonio Independent School District v. Laura Becerra (as Next Friend of J.C.)

Court
CA Texas
Jurisdiction
USA
Decided
2026-08-05
AI tool
Implied
Outcome
Admonishment
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Brief cited a non-existent opinion styled 'Alief Independent School District v. Lozano, 543 S.W.3d 118 (Tex. App.—Houston [14th Dist.] 2018, pet. denied)'; court could not locate any such opinion and found the citation fabricated. || Fabricated: Case Law | Brief cited 'Hoffman v. ESD 48, No. 01-14-00676-CV (Tex. App.—Houston [1st Dist.] 2015, pet. denied)'; court found no such appellate opinion under that style or cause number and treated it as fabricated. || Fabricated: Case Law | Brief cited 'Neely v. West Orange-Cove Consol. ISD, No. 09-17-00196-CV (Tex. App.—Beaumont 2018, no pet.)'; court determined the cited cause number and style did not correspond to an opinion on the subject cited and classified it as fabricated. || Misrepresented: Case Law | Brief cited 'Cutrer v. Tarrant County College District, 943 F.3d 265 (5th Cir. 2019)'; court found the citation conflated or misstyled a real Fifth Circuit employment-discrimination opinion and that the decision does not support the school-law proposition advanced.

Sanction teardown · CA Texas, USA · 2026-08-05

San Antonio Independent School District v. Laura Becerra (as Next Friend of J.C.)

What happened

In CA Texas, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Brief cited a non-existent opinion styled 'Alief Independent School District v. Lozano, 543 S.W.3d 118 (Tex. App.—Houston [14th Dist.] 2018, pet. denied)'; court could not locate any such opinion and found the citation fabricated.
  • Fabricated (Case Law)
    Brief cited 'Hoffman v. ESD 48, No. 01-14-00676-CV (Tex. App.—Houston [1st Dist.] 2015, pet. denied)'; court found no such appellate opinion under that style or cause number and treated it as fabricated.
  • Fabricated (Case Law)
    Brief cited 'Neely v. West Orange-Cove Consol. ISD, No. 09-17-00196-CV (Tex. App.—Beaumont 2018, no pet.)'; court determined the cited cause number and style did not correspond to an opinion on the subject cited and classified it as fabricated.
  • Misrepresented (Case Law)
    Brief cited 'Cutrer v. Tarrant County College District, 943 F.3d 265 (5th Cir. 2019)'; court found the citation conflated or misstyled a real Fifth Circuit employment-discrimination opinion and that the decision does not support the school-law proposition advanced.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Admonishment

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/2781/San_Antonio_Independent_School_District_v._Laura_Becerra_USA_5_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2781/San_Antonio_Independent_School_District_v._Laura_Becerra_USA_5_August_2026.pdf

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