Stanford v. Leinart
Court of Appeals of Texas, Second District (Fort Worth) · Tex. App. · Texas bar guidance
Verified May 14, 2026
- Citation
- Stanford v. Leinart, No. 02-25-00529-CV (Tex. App. Apr. 2, 2026) (Walker, J.) (mem. op.)
- Decided
- April 2, 2026
Summary
Jason Stanford, proceeding pro se, appealed a trial court order that declared him a vexatious litigant and sanctioned him for filing a false and misleading document. The Court of Appeals of Texas in Fort Worth, in a memorandum opinion by Justice Walker, found his appellate brief inadequate in nearly every respect. Among the defects, the court identified a cited case it could not find: it "appears to be a hallucinated authority generated from the use of artificial intelligence." The closest real case the court could locate was an unrelated Kentucky workers' compensation decision.
- AI tool:
- Unidentified (the court found a 'hallucinated' authority 'generated from the use of artificial intelligence'; no specific tool named)
What sanction did the court impose?
The court affirmed the trial court's order. It held that Stanford had waived his issues on appeal by failing to comply with the briefing rules, and that the inadequate brief, including the hallucinated citation, could not preserve any error for review. The appellate court imposed no new sanction; it left the trial court's vexatious-litigant and sanctions order in place.
Why does Stanford v. Leinart matter for law firms using AI?
Stanford v. Leinart is an appellate court treating a hallucinated citation as one more piece of an already-fatal briefing failure. Stanford, declared a vexatious litigant below and sanctioned for a false filing, appealed pro se. The Fort Worth Court of Appeals never reached the merits. His brief did not comply with the rules, and one of its citations pointed to a case that does not exist, which the court described as a “hallucinated authority generated from the use of artificial intelligence.”
The court quoted a Dallas Court of Appeals line that “citation of nonexistent cases that appear to have been generated by artificial intelligence is unacceptable,” then affirmed on waiver. For a firm defending a judgment on appeal in Texas, the pattern is the one that recurs across the state appellate cases: the hallucinated cite does not trigger a separate sanctions proceeding at the appellate level. It feeds the briefing-waiver analysis, and the briefing-waiver analysis ends the appeal.