IN RE PAULA M. MILLER, Relator
AC Texas · Apr 23, 2026
- Jurisdiction
- state
- Court
- AC Texas
- Record ID
- in-re-paula-m-miller-relator-2026-04-23
- Observed outcome
- The court issued a warning to counsel regarding the duty of candor and the necessity of verifying AI-generated research.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to counsel regarding the submission of AI-hallucinated citations. It established that relying on generative AI without human verification violates the duty of candor and warned that future infractions would lead to the striking of briefs and potential reporting to the State Bar.
The court reasoned that filing documents with fictitious or misleading citations constitutes a breach of the duty of candor, regardless of whether the content was generated by AI. The court held that counsel has an affirmative ethical duty to 'trust and verify' the accuracy of research results.
This case serves as a clear judicial directive that the duty of candor applies to AI-generated content. It establishes that courts will treat unverified AI hallucinations as a professional ethics violation, with potential for sanctions including brief striking and disciplinary referrals.
Failure modes and consequences
- Other
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- generative AI
- Known monetary consequence
- Not recorded
- Procedural posture
- Original proceeding on a petition for writ of mandamus.
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 refers to the use of generative AI for legal research.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory human verification protocols for all legal research generated by AI tools.
- Establish a policy requiring counsel to confirm that cited cases exist and support the propositions for which they are used.
- Review internal filing procedures to ensure compliance with the duty of candor regarding AI-assisted research.