Truong v. Flint Hills Resources, LLC
U.S. District Court, Southern District of Texas, Corpus Christi Division · S.D. Tex. · Texas bar guidance
Verified May 5, 2026
- Citation
- Truong v. Flint Hills Resources, LLC, No. 2:24-cv-00310 (S.D. Tex. Apr. 14, 2025) (Second Show Cause Order)
- Decided
- April 14, 2025
Summary
Plaintiffs' attorneys Ashkan Attar (Attar Law Group, PLLC) and Alfonso Nevarez (Nevarez Williams) submitted a response to a motion to dismiss and a sur-reply containing multiple fabricated or misrepresented case citations, including cases that could not be located by their reporter numbers (New Orleans Louisiana Saints, L.L.C. v. NFL; Pecos Valley Artesian Conservancy Dist. v. Tex. & N. O. R. Co.; Boudreaux v. ExxonMobil Corp.) and cases cited for propositions the opinions did not support (Brooks v. Ross; Krys v. Pigott; In re Toyota; In re Deepwater Horizon; Turner v. Big Lake Oil Co.; Tanglewood E. Homeowners; Rubin v. Yellow Cab; Alm v. Aluminum Co.; Missouri v. Illinois; Illinois v. City of Milwaukee; Walker v. Tex. Elec. Serv.; Canton-Carter v. Baylor College of Medicine; Horizon Shipbuilding). When opposing counsel detailed the errors in a reply, plaintiffs' counsel filed a sur-reply that did not defend or withdraw the briefing. Judge Nelva Gonzales Ramos issued a Second Show Cause Order finding that several citations "appear to have been invented" and ordering counsel and their firms to appear in person to show cause why they should not be sanctioned under Rule 11, the court's inherent powers, S.D. Tex. Local Rules, and the Texas Disciplinary Rules of Professional Conduct.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause issued April 14, 2025, requiring lead attorney Ashkan Attar, attorney Alfonso Nevarez, representatives of Attar Law Group, PLLC and Nevarez Williams, and any other attorney who drafted the response or sur-reply to appear in person on May 14, 2025 in Corpus Christi. The court reserved the full range of sanctions, including disciplinary referral to the chief judge and the State Bar of Texas Chief Disciplinary Counsel, monetary penalties, fee-shifting, and discipline up to suspension or disbarment from the Southern District of Texas.
Why does Truong v. Flint Hills Resources, LLC matter for law firms using AI?
Truong is unusual in two respects useful to a managing partner. First, the hallucination pattern was not a single fabricated case but a dense pattern of citation manipulation across at least fourteen authorities, mixing wholly invented cases, wrong-jurisdiction cites, and accurate cites paired with fictitious parentheticals, the signature of unverified generative AI output run through legal briefing without a citation check. Second, plaintiffs’ counsel chose not to defend or withdraw the briefing when opposing counsel and the court flagged the errors, converting a recoverable Rule 11 mistake into a referral-grade ethics matter implicating Texas Disciplinary Rules 3.01, 3.02, 3.03(a), and 8.04(a).
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.
- AI tool identification as ChatGPT: the April 14, 2025 Second Show Cause Order does not name a specific generative AI product. Charlotin's index attributes the briefing to ChatGPT, but the court's order describes the citations as appearing 'to have been invented' without identifying the tool. Final sanctions order, if issued after the May 14, 2025 hearing, may name the tool.
- CLE commitment outcome: the April 14, 2025 order is the show cause order, not the final sanctions order. Any CLE training requirement would have been imposed at or after the May 14, 2025 hearing and is not reflected in the document verified here.