Stanford v. Leinart
Court of Appeals of Texas, Second District (Fort Worth) · Tex. App. · Texas bar guidance
Verified October 1, 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 did the court warn about?
The court declined the appellee's request to summarily affirm for briefing waiver ("Because we can ascertain the issues he intends to present for our review, we will reach the merits of Stanford's appeal"), overruled all seven issues, and affirmed the order declaring Stanford a vexatious litigant. It found his "gross misrepresentations of the record and misstatements of the law are unacceptable" and, addressing a fabricated quotation, stated: "We admonish Stanford for making such a fabricated claim and attempting to mislead this court" (pp. 22-23). 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, declared a vexatious litigant below and sanctioned for a false filing, appealed pro se. His brief did not comply with the briefing rules, and one of its citations pointed to a case that does not exist; the Fort Worth Court of Appeals said the case “is a fabricated case and appears to be a ‘hallucinated’ authority generated from the use of artificial intelligence” (fn. 11). The court nonetheless reached the merits.
In a footnote identifying the fabricated case, the court quoted a Dallas Court of Appeals statement that “[c]itation of nonexistent cases that appear to have been generated by [artificial intelligence] is unacceptable.” It admonished Stanford for a fabricated quotation but declined to affirm on briefing waiver, reaching and rejecting each of his seven issues instead. For a firm defending a judgment on appeal in Texas, the case shows an appellate court identifying hallucinated authority and admonishing the filer without opening a separate sanctions proceeding.