Ericka Holmes v. The University of Texas at Austin
W.D. Texas · Feb 4, 2026
- Jurisdiction
- federal
- Court
- W.D. Texas
- Record ID
- ericka-holmes-v-the-university-of-texas-at-austin-2026-02-04
- Observed outcome
- The court denied the motion for reconsideration and issued a show cause order for counsel to appear and explain the use of hallucinated citations and mischaracterized authority.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a show cause order against Plaintiff's counsel, Gary Bledsoe, following the submission of a motion for reconsideration containing a hallucinated case citation and multiple mischaracterizations of legal authority. The court ordered counsel to provide a written explanation and appear at a hearing to address potential violations of Rule 11 and professional conduct standards.
Fabricated: Case Law | Counsel cited a nonexistent Fifth Circuit case 'Harris v. City of Houston (5th Cir. 2022)' to support an 'age-specific references' standard; court found the case does not exist and labeled it a hallucinated case. || Misrepresented: Case Law | Counsel attributed to Lenzi v. Systemax, Inc. a holding that 'discrimination claims may proceed without traditional comparator evidence,' which the court found to be a mischaracterization of Lenzi. || Misrepresented: Case Law | Counsel relied on Hamilton v. Dallas County as if it pertained to the comparator pleading requirement; the court found that Hamilton is unrelated to that element and was mischaracterized. || Misrepresented: Exhibits & Submissions | Multiple citations were improperly formatted or incorrect (examples flagged by the court), indicating inaccurate or AI-generated citation errors.
Hallucinated Fifth Circuit cites draw show-cause orders; require supervising attorney sign-off on every cite in employment briefs.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Employment
- Trial
- None Adjudicated
- AI attribution
- Reported
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court issued a show cause order following the denial of Plaintiff's Motion for Reconsideration and Motion for Leave to Amend Complaint.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court identified the errors as hallmarks of generative AI use.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Retain a matter-level record of source checks and corrections.
- Assign a responsible reviewer for AI-assisted research and drafting.