Published opinion, 5 August 2026 · source · PDF · 13 pages
CODE § 51.014(a)(8). ANALYSIS Becerra’s Cited Authority 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.
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.
SAISD’s reply brief expressly identifies this citation as a hallucination.
Becerra cites this hallucination for the proposition that “Texas courts have recognized that interference with a student’s educational rights can give rise to a justiciable injury,” and she identifies it as “finding jurisdiction where a district acted beyond its authority in removing a student from a program without due process.” In other words, Becerra relies on this hallucination as a core par t of her argument to this court. She does not offer any further authority to support the propositions she attributes to this hallucination. • “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. Our searches of Westlaw and the website for the Houston First Court of Appeals show that cause number 01-14-00676 was assigned to a criminal case in the relevant year.
09-17-00196-CV (Tex. App.—Beaumont 2018, no pet.),” cited on page 21 of Becerra’s brief, does not exist. Our searches of Westlaw and the website for the Beaumont Court of Appeals show that cause number 09-17-00196 was assigned to a criminal case in the relevant year.
See generally 943 F.3d at 267–68. Becerra contends that she cited the Hoffman, Neely, and Cutrer hallucinations identified above to refute SAISD’s own reliance on those citations. But SAISD did not cite any of these fictitious opinions in either its appellate briefing or its trial court filings.
3.03(a)(1). 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 .” See TEX.