San Antonio ISD Mom’s Lawyer Admonished Over AI “Hallucinations”

Texas Fourth Court of Appeals (San Antonio)
Ruling: An ISD has lawsuit immunity for the discipline assessed to a student for taking a “Montessori knife” to school and for being disruptive — and the lawyer for the student’s mother is admonished for apparently using AI to generate fake legal arguments.

• San Antonio ISD v. Laura Becerra, as next friend of J.C., a minor, No. 04-25-00724-CV ($). Issued Aug. 5, 2026.

Background

This dispute arose after a fifth-grade student at San Antonio ISD (SAISD) Mark Twain Dual Language Academy brought a Montessori knife to school, used it to cut fruit at lunch, and later admitted he had planned to use it in a game but did not. (A parent’s tip led to the discovery that the student had the knife, which the district determined to fall within the school-policy definition of a prohibited knife.)

The student was suspended for 2-1/2 days and, after a disciplinary hearing, was assigned to a disciplinary alternative education program (DAEP) for 25 days for possessing a knife and engaging in disruptive conduct (by writing threatening “I hate you now…”) notes to several students after returning to the school from suspension.

His mother sued the district (and two SAISD administrators), arguing the punishment violated due process, was arbitrary and capricious, and that the district exceeded its legal authority. The mother was particularly upset that the student’s temporary DAEP placement removed him from the school’s dual language program.

SAISD appealed after the trial judge refused to dismiss the lawsuit against the district itself. (The judge dismissed the claims against the two administrators.)

Dismissed

A three-member Fourth Court appellate panel, in this unanimous decision, sided with SAISD and ordered the litigation dismissed.

The justices:

• Concluded that the Texas Education Code does not permit courts to review the merits of DAEP placement decisions.

• Found the student’s constitutional claims were not viable because he was not denied access to a public education — but was only transferred to a different educational setting.

AI “Hallucinations” Warning

In a notable portion of the opinion, the justices criticized the family’s appellate brief for citing four legal cases that did not exist or inaccurately described existing cases.

The justices noted prior judicial warnings to attorneys that generative artificial intelligence can produce fictitious legal citations, and reminded the family’s lawyer — and all lawyers — of the duty to verify legal citations before filing briefs.

“We once again repeat that admonition,” the justices stated.

The justices, however, declined to dismiss the lawsuit solely on the AI-generated briefings by the family’s attorney, and instead ordered dismissal on the legal merits of the dispute.