Adams v. Butler Construction: Texas Court Affirms $14,271 Sanctions Against Pro Se Litigant Who Used AI to Fabricate Case Citations | Advocate Prakhar

Case at a Glance

Full Citation	Adams v. Allen Butler Construction, Inc., No. 07-25-00191-CV (Tex. App.—Amarillo May 5, 2026)
Court	Court of Appeals, Seventh District of Texas at Amarillo
Date	May 5, 2026
Category	AI Hallucination — Fabricated Citations; Discovery Sanctions
Jurisdiction	United States — Texas
AI Tool Used	Unspecified AI tool (implied from fabricated citations pattern)
Outcome/Sanction	$14,271.25 attorney’s fees affirmed as discovery sanctions; appellate issues waived due to deficient briefing

Background

Amanda Adams, appearing without a lawyer, sued Allen Butler Construction, Inc. (ABCI) in Lubbock County, Texas, alleging disability discrimination, retaliation, breach of contract, and unjust enrichment arising from her employment. The case was marked by repeated discovery disputes: Adams failed to comply with multiple court orders requiring her to produce documents and eventually revoked all third-party record authorizations, claiming she was protecting them from tampering.

The trial court granted ABCI’s motion to compel and for sanctions. After Adams filed — and then tried to withdraw by email — a motion to dismiss, the court entered an order awarding ABCI $14,271.25 in attorney’s fees as discovery sanctions and dismissing Adams’s claims without prejudice.

The AI Issue

When Adams appealed, she submitted a brief containing cases that did not exist, quotations attributed to real cases that those cases did not contain, and inaccurate descriptions of the clerk’s and reporter’s records. This was not the first warning: the trial court had explicitly told Adams that “any further blatant misrepresentations of case law will not be permitted and may result in the issuance of sanctions. The use of artificial intelligence in preparation of a submission to the Court will not excuse misrepresentations of case law.” The appellate court independently reviewed her brief and confirmed ABCI’s characterisation — the citations and quotations were fabricated.

What the Court Decided

• A pro se litigant is held to exactly the same standard as a licensed attorney — AI use does not create a lower bar [equal standards for all court participants].
• An appellate brief citing non-existent cases or containing fabricated quotations fails Rule 38.1(i) of the Texas Rules of Appellate Procedure and presents nothing for review [waiver by inadequate briefing].
• Using AI to prepare a brief “could be grounds for striking” the brief — citing an earlier San Antonio appellate ruling [risk of struck briefs for AI hallucinations].
• The $14,271.25 attorney’s fees sanction was affirmed — and would have been affirmed even without the waiver finding because Adams’s underlying claims failed on the merits [dual-basis affirmance].
• Adams could not unilaterally withdraw her motion to dismiss via email after it had already become effective upon filing [procedural point on nonsuits].

“The use of artificial intelligence in preparation of a submission to the Court will not excuse misrepresentations of case law.”

— Trial Court (Judge Les Hatch, 237th District Court, Lubbock County), as quoted by the Court of Appeals, May 5, 2026

The India Angle

Indian Law Equivalent

Order XI of the Code of Civil Procedure, 1908 governs discovery and inspection. Repeated failures to comply with discovery orders, as Adams demonstrated, can lead to striking of pleadings and adverse inferences. For the AI citation issue, Rule 18 of the Advocates Act, 1961 and the Contempt of Courts Act, 1971 provide the framework for addressing false statements to courts.

Bar Council Rules

Bar Council of India Rule 22 prohibits an advocate from making false statements to the court. Rule 15 requires fair conduct. Rule 33 deals with conduct in court — an advocate must not mislead the court. These rules apply with equal force whether the false statement originates from the advocate’s own research or from an AI tool the advocate failed to verify.

Practical Advice for Indian Advocates

• Verify every case citation using SCC Online, Manupatra, or the Supreme Court’s own website before filing — AI systems trained on foreign data can hallucinate Indian case names and citations.
• When assisting pro se clients with draft documents, ensure they understand that courts will hold them to professional standards regardless of how the draft was prepared.
• Keep a verification checklist: for each case cited, note the database searched, the search date, and the page reference — this creates an audit trail if citations are questioned later.

Quick Takeaways

• AI use never lowers the standard — pro se litigants bear the same responsibility as attorneys.
• Fabricated citations waive all appellate issues automatically under Texas rules.
• Courts can strike AI-hallucinated briefs entirely, not just dismiss the arguments.

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Deep Dive: The “Equal Standards” Rule and the Pro Se AI Problem

Adams v. Butler Construction highlights a growing tension in courts worldwide: self-represented litigants increasingly use AI tools to level the playing field against professionally represented opponents, but AI hallucinations can destroy their cases entirely. The Seventh District’s ruling is a clear signal that courts will not lower the verification standard simply because a party lacks legal training.

The background facts reveal a litigant who was already in significant procedural trouble before the AI issue surfaced. Adams had defied multiple discovery orders, revoked third-party record authorizations, and been formally warned that misrepresentations would result in sanctions. The trial court’s warning — that AI use “will not excuse misrepresentations” — was a direct, explicit, on-the-record admonition. When Adams continued to file a brief at the appellate level that the court independently confirmed contained non-existent cases and fabricated quotations, she had no plausible defense.

The appellate court cited a 2026 San Antonio decision noting that AI use in preparing a brief “could be grounds for striking” it. This is significant: the remedy is not merely a dismissed argument or a waived issue but the wholesale removal of the entire brief from the court’s consideration. For any litigant — pro se or represented — having an entire brief struck is catastrophic. All issues are deemed waived. The opposing party wins without the court needing to reach the merits.

The $14,271.25 sanction in this case was actually grounded in discovery misconduct rather than the AI citation failures — it was attorney’s fees awarded to ABCI for the months of discovery battles Adams conducted. But the appellate court’s independent confirmation of the AI-generated citation problem meant that Adams’s appeal had no vehicle: she had waived every issue by filing a deficient brief. The combination of discovery sanctions affirmed and appeal waived meant Adams left the litigation owing nearly $14,300 with no appellate path remaining. For Indian advocates advising clients on litigation strategy, this case is a cautionary tale about compounding procedural failures — each individual error (discovery non-compliance, AI brief preparation, failure to verify citations) reinforced the others, leaving no viable legal position intact.