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Rochon-Eidsvig v. JGB Collateral, LLC

Texas Court of Appeals, Fifth District at Dallas · Tex. App. (5th Dist.) · Texas bar guidance

Court sanction

Verified May 5, 2026

Citation
Rochon-Eidsvig v. JGB Collateral, LLC, No. 05-24-00123-CV (Tex. App.—Dallas June 12, 2025) (order)
Decided
June 12, 2025

Summary

Appellants' counsel Heidi R. Hafer filed a brief in this contract appeal containing four citations to nonexistent cases that neither the court nor opposing counsel could locate. After a show-cause process and a May 8, 2025 hearing, at which Hafer appeared with retained counsel former Justice John G. Browning, the panel led by Justice Nancy Kennedy found the citations were generated by an unverified online research tool and not confirmed against primary sources. Hafer acknowledged the lapse as a humbling and embarrassing oversight.

AI tool:
Unspecified generative AI
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

The court ordered Hafer to complete eight hours of Texas continuing legal education within a set period: three hours on legal ethics and five hours on artificial intelligence in legal practice, with proof of completion filed with the court. No monetary penalty was imposed.

Why does Rochon-Eidsvig v. JGB Collateral, LLC matter for law firms using AI?

Rochon is notable as one of the first Texas appellate orders to require AI-specific CLE as a sanction component, splitting the eight-hour requirement between ethics and AI literacy. For a managing partner, the takeaway is that Texas appellate panels are now treating unverified citation practices as an AI-competence failure, not a generic Rule 11 lapse, and tailoring discipline accordingly.

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Sanctions cases

From the blog

Sources

Primary sources

Further reading

Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.

Unverified claims:
  • Names of the four fabricated cases were not extractable from the available copies of the order.
  • The specific generative AI product is not named in the order; the court characterizes the source as an unverified online research tool.