A San Antonio appeals court dismissed a mother's lawsuit against San Antonio Independent School District over her fifth-grade son's school discipline, ruling that state courts have no authority to review the case — and rebuking her attorney for citing four court decisions that either did not exist or did not say what he claimed. The case traces back to September 10, 2025, when 10-year-old Julian Cortez was detained, suspended, and ultimately assigned to a 25-day alternative school program after bringing a child-safe Montessori fruit knife to Mark Twain Dual Language Academy in his lunchbox.
The Fourth Court of Appeals ruled Wednesday that Texas law generally does not allow courts to review disciplinary decisions placing students in alternative education programs, according to the San Antonio Expraess-News. Justice Lori Valenzuela authored the opinion, which found that Laura Becerra, the boy's mother, failed to state a viable constitutional claim after arguing the district had violated her son's rights and had acted beyond its legal authority by reopening the disciplinary matter and imposing a harsher punishment. State District Judge Mary Lou Alvarez had originally refused to dismiss the lawsuit, concluding the court had jurisdiction to hear the claims, before the appellate panel reversed that decision.
Judges Say Citations Were AI Hallucinations
Beyond the jurisdictional ruling, the appeals court's opinion focused heavily on the legal research submitted by Becerra's attorney, Juan Antonio Lozada, who represented her in the appeal and urged the court to uphold Alvarez's original ruling. After conducting an extensive search of legal databases, the court found that three cases cited in Lozada's brief did not exist at all, while a fourth — a Fifth U.S. Circuit Court of Appeals decision described in the brief as a school discipline case — had actually involved an employment discrimination lawsuit. The court said the citations appeared to be hallucinations created by generative AI, and it rejected Lozada's explanation for three of the citations. Lozada did not respond to requests for comment from the newspaper.
One case cited in the brief, Alief Independent School District v. Lozano, could not be found in any legal database the court searched. The Fourth Court of Appeals noted that SAISD's own attorneys had not cited those same three cases in either the trial court or on appeal, underscoring that the fabricated authority originated solely from Becerra's side. Justice Valenzuela wrote that licensed attorneys owe a duty of candor to the court and a duty of competence to their clients, and she cited an earlier opinion warning that AI tools lack the ability to produce reliable and accurate citations to legal authorities. The panel considered throwing out Lozada's brief entirely and warned that similar problems would not be tolerated in future appearances before the court.
Discipline Was Already Reversed Internally
Notably, the San Antonio ISD Board of Trustees had already voted unanimously in May to overturn the boy's 25-day alternative-school placement, seven months after the original decision — action that came before the appeals court issued its opinion. That internal reversal did not stop the district from continuing its appeal, which sought to establish that Texas courts lack authority to review these placements in the first place. Under Section 37.009 of the Texas Education Code, school district decisions placing a student in a Disciplinary Alternative Education Program are generally final at the board level and exempted from judicial review, according to a legal digest published by ED311. That statutory framework gave the district a jurisdictional shield even though its own board had already conceded the punishment was excessive.
Texas Courts Crack Down on AI-Generated Filings
The San Antonio case lands amid a broader judicial reckoning over unverified generative AI use in legal filings. The Texas Supreme Court has given preliminary approval to proposed rules that would require attorneys to explicitly verify that legal citations and quotations in their filings are authentic, with appellate courts empowered to throw out all or part of a noncompliant filing or impose monetary sanctions. Texas courts have repeatedly warned that AI tools can fabricate legal citations, and have called on attorneys to independently verify anything generated by such tools before filing it.
The problem is not confined to Texas or to state courts. In June, a federal court in North Texas confronted a similar dispute in A2K Inc. v. Fluor Corp., in which a subcontractor admitted using generative AI to draft a response brief that included a nonexistent Texas Supreme Court quote, according to Jones Walker LLP. Globally, the HAQQ AI Hallucination Cases database has tracked a surge in identified court cases involving AI-fabricated legal citations, from roughly 200 in mid-2025 to nearly 1,600 by June 2026, with U.S. courts levying more than $145,000 in penalties during the first quarter of 2026 alone, per HAQQ. The national landmark case remains Mata v. Avianca, Inc., in which a New York federal judge in 2023 imposed $5,000 in sanctions on two attorneys who submitted a ChatGPT-drafted brief containing six fabricated judicial opinions after finding they had acted in subjective bad faith.
The American Bar Association addressed the issue directly in a 2024 ethics opinion establishing that lawyers using generative AI tools owe duties of competence and candor to the court, requiring human verification of all AI-generated research before it is filed. That standard is precisely what the Fourth Court of Appeals found lacking in Lozada's brief on behalf of Becerra.
A District Already Under Financial Strain
The dispute also played out against the backdrop of San Antonio ISD's ongoing budget crisis. The district has been navigating a 2023–2024 rightsizing plan that shuttered 19 schools, and in March it proposed eliminating more than 220 jobs to close a $46 million budget gap. Even as it pressed forward with layoffs and campus closures, the district continued to fund a legal appeal aimed at preserving its authority over disciplinary decisions like the one it had already reversed for Julian Cortez. Whatever the outcome for one family, the ruling leaves intact the broader legal principle that Texas courts generally cannot second-guess a school board's discipline decisions — fake citations or not.
