In Re Paula M. Miller v. the State of Texas

Opinion issued April 23, 2026

In The

Court of Appeals
For The

First District of Texas
————————————
NO. 01-26-00319-CV
———————————
IN RE PAULA M. MILLER, Relator

Original Proceeding on Petition for Writ of Mandamus

MEMORANDUM OPINION

Relator Paula M. Miller has filed a petition for writ of mandamus

challenging the Fort Bend County Democratic Party Chairwoman’s ruling that

declared relator ineligible for the general election.

A relator has the burden to file a complete record showing entitlement to

mandamus relief. TEX. R. APP. P. 52.7(a). The relator here has not filed such a

record. We deny mandamus relief. Id. We dismiss any pending motions as moot.
PER CURIAM
Panel consists of Chief Justice Adams and Justices Caughey and Morgan.
Adams, C.J., concurring.

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Concurring Opinion issued April 23, 2026

In The

Court of Appeals
For The

First District of Texas
————————————
NO. 01-26-00319-CV
———————————
IN RE PAULA M. MILLER, Relator

Original Proceeding on Petition for Writ of Mandamus

CONCURRING OPINION

I write separately to note that the mandamus petition here has attributions

and quotations to caselaw which strongly appear to be AI-fabricated hallucinations.

Filing a document in our Court with fictitious or misleading citations—whether

generated by AI and not checked by a human, or otherwise—is a serious breach of

candor that this Court cannot tolerate. See TEX. R. APP. P. 38.1, 38.9; Schlafly v.

Schlafly, 33 S.W.3d 863, 873 (Tex. App.—Houston [14th Dist.] 2000, pet. denied).
“Citing nonexistent case law or misrepresenting the holdings of a case is making a

false statement to a court. It does not matter if [generative AI] told you so.”

United States v. Hayes, 763 F. Supp. 3d 1054, 1067 (E.D. Cal. 2025) (quoting

Maura R. Grossman, Paul W. Grimm, & Daniel G. Brown, Is Disclosure and

Certification of the Use of Generative AI Really Necessary?, 107 Judicature 68, 75

(2023)).

Counsel who appear before this Court and use AI for legal research must do

so with great care. Always “trust and verify” the accuracy and validity of your

results. Trusting AI for legal research without verifying that the cases actually

contain quoted language and stand for the proposition for which they are cited

violates counsel’s ethical duty to this Court. And that unfortunately will require

the Court to take the necessary corrective action including, but not limited to,

striking the offending brief and reporting counsel to the State Bar.

Terry Adams
Chief Justice

Panel consists of Chief Justice Adams and Justices Caughey and Morgan.

Adams, C.J., concurring.

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