In the Interest of M. O. W.
Court of Appeals of Texas, Austin · Tex. App.—Austin · Texas bar guidance
Verified September 30, 2026
- Citation
- In the Interest of M. O. W., No. 03-25-00705-CV, 2025 WL 3114015 (Tex. App.—Austin Nov. 7, 2025, no pet.) (mem. op.)
- Decided
- November 7, 2025
Summary
Appellant Oliver Densil Watts, appearing pro se, filed responses opposing dismissal of an interlocutory appeal from a Uniform Interstate Family Support Act proceeding. The Third Court of Appeals (Justices Triana, Kelly, and Theofanis; opinion by Justice Gisela D. Triana) found that several of the cases Watts cited in support of appellate jurisdiction did not exist, describing them as apparent AI hallucinations, and that the remaining cited authorities did not support the propositions for which they were offered.
- AI tool:
- Unspecified generative AI
How did the court address the AI-related conduct?
Appeal dismissed for want of jurisdiction under Tex. R. App. P. 42.3(a). The opinion identified the fabricated citations on the record but did not impose monetary sanctions, suspension, or a bar referral.
Why does In the Interest of M. O. W. matter for law firms using AI?
The Third Court dismissed the underlying interlocutory appeal for want of jurisdiction and used the same memorandum opinion to identify the AI-hallucinated citations in the pro se appellant’s responses. No fine, suspension, or referral followed. What the case demonstrates is the routine: Texas appellate panels are now flagging fabricated authorities sua sponte during jurisdictional review. A brief carrying a firm’s name needs every cite to clear that gate before filing, because the next panel that catches a fabrication will not always extend the same forbearance the Third Court extended here.