In re Scott Mitchell Obeginski
Texas Court of Appeals, Ninth District · Tex. App. (9th Dist.) · Texas bar guidance
Verified May 15, 2026
- Citation
- In re Obeginski, No. 09-26-00057-CV (Tex. App. Beaumont Mar. 12, 2026) (mem. op.)
- Decided
- March 12, 2026
Summary
Pro se litigant Scott Mitchell Obeginski sought mandamus relief from a trial court order entered after he repeatedly cited fictitious case authorities in his filings. The Ninth Court of Appeals (Chief Justice Golemon, Justices Wright and Chambers) denied the petition and upheld the trial court's directive. The order requires Obeginski, in any future filing in any court, to attach a copy of every legal authority he cites and to highlight the portion supporting the proposition for which it is cited.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Petition for writ of mandamus denied. The trial court's sanction order was affirmed, leaving in place a novel remedy that follows the litigant beyond the originating court: every future filing in any court must include highlighted copies of all cited authorities. The court found a direct relationship between the offensive conduct, repeatedly citing fictitious cases, and the sanction imposed.
Why does In re Scott Mitchell Obeginski matter for law firms using AI?
Obeginski is notable for the breadth of its remedy. Most fabricated-citation sanctions reach only the case at hand, but the Ninth Court of Appeals affirmed an order that follows the litigant into every future filing in any court, requiring him to attach and highlight each cited authority. For firms tracking how courts are escalating responses to AI-assisted hallucinations, this case marks a meaningful expansion of the available judicial toolkit beyond fines and case-specific strikes.
Sources
Primary sources
Further reading
- The specific generative AI tool used was not named in the opinion or in available secondary coverage (confirmed against the Volokh Conspiracy summary on 2026-05-15; the appellate opinion uses generic "fictitious cases" / "fictitious legal authority" phrasing).
- The opinion does not enumerate the particular fabricated case names (confirmed against the Volokh Conspiracy summary on 2026-05-15; neither the appellate opinion nor public coverage lists the specific fictitious citations).