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Suday v. Suday

Court
CA Texas
Jurisdiction
USA
Decided
2026-01-14
AI tool
Implied
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Supplemental brief cited 'Varela v. Varela, 464 S.W.3d 407 (Tex. App.—San Antonio 2015, no pet.)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Garrison v. Garrison, 966 S.W.2d 493, 495 (Tex. App.—San Antonio 1998, no pet.)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Ex parte Hudson, 11 U.S. 225, 234 (1812)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Sabir v. Daud, No. 01-22-00956-CV, 2024 WL 3478110, at 5 (Tex. App.—Houston [1st Dist.] July 18, 2024, no pet.)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Douglas v. Douglas, 454 S.W.2d 225, 227 (Tex. Civ. App.—Galveston 1970, no writ)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Woodard v. Andrus, 419 S.W.3d 226, 234 (Tex. App.—Beaumont 2013, pet. denied)', which court could not locate and deemed likely fictitious.

Details

The court found that nearly all caselaw cited in the appellant's supplemental brief could not be located and appears fictitious; the court suggested the use of an AI tool but chose to address the merits and issued a caution about reliance on such tools.

Sanction teardown · CA Texas, USA · 2026-01-14

Suday v. Suday

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)
    Supplemental brief cited 'Varela v. Varela, 464 S.W.3d 407 (Tex. App.—San Antonio 2015, no pet.)', which court could not locate and deemed likely fictitious.
  • Fabricated (Case Law)
    Supplemental brief cited 'Garrison v. Garrison, 966 S.W.2d 493, 495 (Tex. App.—San Antonio 1998, no pet.)', which court could not locate and deemed likely fictitious.
  • Fabricated (Case Law)
    Supplemental brief cited 'Ex parte Hudson, 11 U.S. 225, 234 (1812)', which court could not locate and deemed likely fictitious.
  • Fabricated (Case Law)
    Supplemental brief cited 'Sabir v. Daud, No. 01-22-00956-CV, 2024 WL 3478110, at 5 (Tex. App.—Houston [1st Dist.] July 18, 2024, no pet.)', which court could not locate and deemed likely fictitious.
  • Fabricated (Case Law)
    Supplemental brief cited 'Douglas v. Douglas, 454 S.W.2d 225, 227 (Tex. Civ. App.—Galveston 1970, no writ)', which court could not locate and deemed likely fictitious.
  • Fabricated (Case Law)
    Supplemental brief cited 'Woodard v. Andrus, 419 S.W.3d 226, 234 (Tex. App.—Beaumont 2013, pet. denied)', which court could not locate and deemed likely fictitious.

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

Warning

Additional detail

The court found that nearly all caselaw cited in the appellant's supplemental brief could not be located and appears fictitious; the court suggested the use of an AI tool but chose to address the merits and issued a caution about reliance on such tools.

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/1310/Suday_v._Suday_USA_14_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1310/Suday_v._Suday_USA_14_January_2026.pdf

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