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Corpus matter record

Suday v. Suday

CA Texas · Jan 14, 2026

Direct answer

What happened in this matter?

The court issued a formal warning to the pro se litigant regarding the use of AI tools for legal research after discovering that nearly all citations in the appellant's supplemental brief were fictitious. The court declined to strike the brief, choosing instead to address the merits of the case.

Why the court cared
Fabricated: Case Law | Supplemental brief cited 'Varela v. Varela, 464 S.W.3d 407 (Tex. App.—San Antonio 2015, no pet.)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Garrison v. Garrison, 966 S.W.2d 493, 495 (Tex. App.—San Antonio 1998, no pet.)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Ex parte Hudson, 11 U.S. 225, 234 (1812)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Sabir v. Daud, No. 01-22-00956-CV, 2024 WL 3478110, at 5 (Tex. App.—Houston [1st Dist.] July 18, 2024, no pet.)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Douglas v. Douglas, 454 S.W.2d 225, 227 (Tex. Civ. App.—Galveston 1970, no writ)', which court could not locate and deemed likely fictitious. || Fabricated: Case Law | Supplemental brief cited 'Woodard v. Andrus, 419 S.W.3d 226, 234 (Tex. App.—Beaumont 2013, pet. denied)', which court could not locate and deemed likely fictitious.
Why it matters now
This record documents a Pro Se Litigant filing issue in CA Texas, with the listed outcome: Warning.

Why this matter is tracked

In Suday v. Suday, the Texas Court of Appeals for the Fourth District addressed an appeal involving a pro se litigant who submitted a supplemental brief containing numerous non-existent legal citations. The court conducted an exhaustive search and determined that the cited authorities were likely fictitious, suggesting the litigant utilized an artificial intelligence tool to generate the brief. Although the court noted that the inclusion of fabricated citations could serve as grounds for striking the brief, it elected to address the merits of the case as remanded by the Texas Supreme Court. The court issued a formal caution to the litigant and others regarding the unreliability of AI tools in producing accurate legal citations.

Operational lesson

This record documents a Pro Se Litigant filing issue in CA Texas, with the listed outcome: Warning.

Record details

TexasSingle-state evidence scope
Explore TXOpen its source-linked jurisdiction page and related matters.
CourtCA Texas
Jurisdictionstate
Circuit5th Circuit
DateJan 14, 2026
UN
AI toolunspecified
Party typePro Se Litigant
OutcomeThe court affirmed the trial court's order and issued a warning regarding the use of AI tools for legal research.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

implied

The court stated the litigant may have used an AI tool.

Procedural posture

Appellate review of a county court order following a remand from the Supreme Court of Texas.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

6 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Supplemental brief cited 'Varela v. Varela, 464 S.W.3d 407 (Tex. App.—San Antonio 2015, no pet.)', which court could not locate and deemed likely fictitious.
  2. Fabricated: Case Law | Supplemental brief cited 'Garrison v. Garrison, 966 S.W.2d 493, 495 (Tex. App.—San Antonio 1998, no pet.)', which court could not locate and deemed likely fictitious.
  3. Fabricated: Case Law | Supplemental brief cited 'Ex parte Hudson, 11 U.S. 225, 234 (1812)', which court could not locate and deemed likely fictitious.
  4. Fabricated: Case Law | Supplemental brief cited 'Sabir v. Daud, No. 01-22-00956-CV, 2024 WL 3478110, at 5 (Tex. App.—Houston [1st Dist.] July 18, 2024, no pet.)', which court could not locate and deemed likely fictitious.
  5. Fabricated: Case Law | Supplemental brief cited 'Douglas v. Douglas, 454 S.W.2d 225, 227 (Tex. Civ. App.—Galveston 1970, no writ)', which court could not locate and deemed likely fictitious.
  6. Fabricated: Case Law | Supplemental brief cited 'Woodard v. Andrus, 419 S.W.3d 226, 234 (Tex. App.—Beaumont 2013, pet. denied)', which court could not locate and deemed likely fictitious.

Questions this record answers

What happened in Suday v. Suday?
The court issued a formal warning to the pro se litigant regarding the use of AI tools for legal research after discovering that nearly all citations in the appellant's supplemental brief were fictitious. The court declined to strike the brief, choosing instead to address the merits of the case.
Why does Suday v. Suday matter for legal AI risk?
This record documents a Pro Se Litigant filing issue in CA Texas, with the listed outcome: Warning.
What does the public record establish about Suday v. Suday?
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.
Which source supports this Suday v. Suday summary?
The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.