Key points:
- Attorney Heidi Hafer admitted to citing four non-existent cases in a Texas appeals court brief.
- The court ordered an explanation after it was unable to locate the referenced cases.
- Hafer stated the citations were not verified from primary sources and described the incident as an oversight.
A Dallas-area attorney has acknowledged citing non-existent legal cases in a court filing after the Texas Fifth Court of Appeals flagged discrepancies in her May 2024 brief. Heidi Hafer, who has been practicing law in Texas since 1999, submitted a response to the court admitting that the references were not verified from primary legal sources.
The appellate court noted that it, along with opposing counsel, was unable to locate four cases cited in the filing. As a result, the court issued an order requiring Hafer to address the issue. In her written explanation, Hafer described the incident as a “humbling and embarrassing lesson” and stated that she relied on case references obtained through online searches without confirming them through official databases.
Hafer also noted that the nature of her legal practice typically does not involve regular citation of mainstream appellate cases. She indicated that this may have contributed to the oversight.
The case in question, Lauren Rochon-Eidsvig and Heidi Rochon Hafer v. JGB Collateral, LLC, is a contract dispute before the Dallas Court of Appeals under case number 5-24-00123-CV. The court has not announced whether further action will be taken in response to the admission.
Similar incidents involving unverified or fictitious legal citations have drawn judicial scrutiny in other jurisdictions. In a separate Pennsylvania case, an attorney was recently sanctioned after submitting filings containing citations that could not be located or were found to contain substantive errors.
The original court documents and filings related to Hafer’s admission are part of the public record. Additional coverage is available through Bloomberg Law.









