Kourradi v. Wyatt Brian Christopher d/b/a NXT-L3VL Mobile Mechanic Fab and Performance

What sanction did the court impose?

In a per curiam memorandum opinion, the court concluded that "[t]he nature of the errors suggests that each of the foregoing legal citations is, at best, partially fabricated." Because the fourth brief failed to correct the identified deficiencies and did not comply with Rule 38.1, the court struck the brief and dismissed the appeal for want of prosecution under Rules 38.9(a), 42.3(b), and 43.2(f), and dismissed any pending motions as moot. The opinion does not describe the strike and dismissal as a sanction; the court acted under its briefing rules in its discretion. It restated that a pro se litigant "is held to the same standard as a licensed attorney and must comply with the Texas Rules of Appellate Procedure." No fine or fee award was imposed. The court's docket shows that Kourradi filed a motion for rehearing on August 21, 2026, and that on September 11, 2026 the court requested a response from the appellee, due September 28, 2026; as of the date this entry was verified, no ruling on rehearing appears on the docket.

Why does Kourradi v. Wyatt Brian Christopher d/b/a NXT-L3VL Mobile Mechanic Fab and Performance matter for law firms using AI?

Kourradi shows the Texas appellate path from admonishment to dismissal. The First Court of Appeals struck two briefs before this opinion. Its second strike order, dated July 16, 2026, noted that “appellant’s brief appears to have been prepared with the assistance of a ‘Legal Research AI’ tool” and stated: “Regardless of whether appellant uses artificial intelligence in the preparation of his corrected brief or not, we admonish appellant to ensure that record references and citations to authorities are accurate.” It supported that admonishment with a See citation to the Austin court’s decision in Campbell v. Campbell, whose parenthetical describes that court admonishing an appellant to “take care not to include hallucinated citations, quotations, or authorities of any kind in the materials that he submits for filing in this Court.” The same order warned that if a compliant corrected brief was not filed, “this appeal will be subject to dismissal without further notice. See TEX. R. APP. P. 42.3(b), (c).”

The opinion’s treatment of the four defective citations in the next brief is methodical. For each one, the court checked the Westlaw identifier, the case number, and the court and date given, and explained where each led: to no authority, to a withdrawn opinion, or to an appeal between different parties. It concluded that “[t]he database identifiers are non-existent, and the appellate case numbers point us to appeals that involve parties different from the parties listed in the citations provided by Kourradi,” and that “[t]he nature of the errors suggests that each of the foregoing legal citations is, at best, partially fabricated.” The opinion does not say how the citations were generated.

The dismissal rests on briefing rules rather than a sanctions finding: the court applied Rule 38.9(a) to strike the noncompliant brief and treated the appeal as one without a brief. A motion for rehearing was pending when this entry was verified. Firms documenting compliance may wish to consider that citation-format artifacts such as invented database numbers are the kind of detail appellate courts now check line by line.